Michael’s clients rely on him for meticulous and innovative tax advice.
Corporations and individuals trust Michael’s advice on the tax aspects of their transactions, both in Canada and internationally. He works with major Canadian, U.S. and other publicly traded companies, private equity and hedge funds and tax-exempt institutions on investments, financings, mergers and acquisitions, reorganizations and real estate and resource projects. Clients also choose Michael to provide counsel on disputes with tax authorities. They rely particularly on his expertise in international tax issues.
Michael is a frequent speaker at tax conferences in Canada and abroad. He is councillor and secretary of the Canadian branch of the International Fiscal Association.
Potash Corporation of Saskatchewan Inc.
Acted as Canadian tax counsel for Potash Corporation of Saskatchewan Inc. in its US$36-billion merger of equals with Agrium Inc. to create the world-class integrated global supplier of crop inputs, Nutrien Ltd. This deal was named 2017's Deal of the Year by Lexpert magazine and won the Mining Deal of the Year award at the 2017 Canadian Dealmakers Awards.
Acted for a U.S. state retirement system in its joint venture with a real estate development company for the acquisition of various industrial properties in Ontario.
Acting as Canadian tax counsel for Nutrien Ltd. and its subsidiary, Potash Corporation of Saskatchewan Inc., in Nutrien's offer to exchange all outstanding publicly held notes of PotashCorp and Agrium Inc. for new notes to be issued by Nutrien.
BNP Paribas S.A.
Acting for BNP Paribas S.A. in connection with an investment by the Caisse de dépôt et placement du Québec in Innocap Investment Management Inc.
BMO Nesbitt Burns Inc.
Acted for a syndicate of agents co-led by BMO Nesbitt Burns Inc., National Bank Financial Inc. and CIBC World Markets Inc. on the following private placement by Metro Inc. to partially finance its acquisition of The Jean-Coutu Group (PJC) Inc.: $1.2 billion aggregate principal amount of 2.68% Series F senior unsecured notes due December 5, 2022; 3.39% Series G senior unsecured notes due December 6, 2027; and 4.27% Series H senior unsecured notes due December 4, 2047.
The Sentient Group
Acted for The Sentient Group in the going-private transaction of Era Resources Inc. effected through a plan of arrangement that included the consolidation of 10,290,619 pre-consolidation common shares of Era to one post-consolidation common share.
Acted for Claridge Inc. in connection with its sale to C.H. Guenther & Son, Inc. of Les Plats du Chef, a Canada-based frozen meal and snack business.
Kruger Inc. Master Trust
Acted for Kruger Inc. Master Trust in connection with the sale of Lidya Energy, a landfill gas-to-electricity plant located in Lachute, Québec, to Energy Developments (Canada) Inc., a subsidiary of Energy Developments Pty Limited, a member of Australia's DUET Group.
Stingray Digital Group Inc.
Acted for Stingray Digital Group Inc. in connection with its acquisition of all the outstanding shares of C Music Entertainment Ltd. (also known as C Music TV).
Acted for a high-net-worth family on tax matters related to a reorganization of the family's corporate holdings.
In the News
Michael Kandev Speaks to Canadian Lawyer About Impact of U.S. Tax Reforms on Canadian Tax Planning
Apr. 05, 2018 - Davies partner Michael Kandev was interviewed this month by Canadian Lawyer (available to subscribers) about the effect of the U.S. Tax Cuts and Jobs Act on Canadian tax planning. One impact of the new legislation has been on the estates of Canadian parents who die in Canada but...
2018 Federal Budget: Tax Highlights
Feb. 27, 2018 - As anticipated, today’s federal budget (Budget 2018) focuses on a few targeted areas, including the taxation of passive investments made by private corporations, and does not contain any measures in response to the enactment of tax reform in the United States or relating to the OECD BEPS initiative....
U.S. Tax Laws: A Review of 2017 and a Look Ahead to 2018
Jan. 11, 2018 - Each year at this time, we offer a look back at some of the more significant income tax developments in the United States affecting domestic and international business over the past year and a look ahead to possible U.S. tax developments in the coming year. Tax Developments in 2017As we predicted...
Canadian Tax Laws: A Review of 2017 and a Look Ahead to 2018
Jan. 11, 2018 - Each year at this time we offer a look back at some of the more significant income tax developments in Canada affecting domestic and international business over the past year and a look ahead to possible Canadian tax developments in the coming year. Developments in 2017 1. Legislative...
Canada Persists With Plan to Punish Private Corporate Passive Reinvestment, co-author
Oct. 30, 2017 - Tax Notes International, Vol. 88, No. 5 (Tax Analysis)
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Unexpected Canadian Private Company Tax Proposals: A Critique And International Comparative
Sept. 04, 2017 - In this article from Tax Notes International, Davies partners Nathan Boidman and Michael Kandev examine proposed plans by the Canadian government for radical changes to the Income Tax Act ostensibly aimed at curbing tax planning using private corporations. Download this article.
Canadian Government Proposes Major Changes to the Taxation of Private Corporations
July 18, 2017 - The Canadian Department of Finance released a discussion paper earlier today on tax planning using private corporations. Included with the paper is draft legislation for a couple of the matters discussed in the paper. Finance has requested comments on the discussion paper by October 2, 2017....
Canada’s Limited Approach to the OECD’s MLI
July 03, 2017 - In this article published in Tax Notes International, Davies partners Nathan Boidman and Michael Kandev discuss Canada’s signing of the OECD multilateral instrument to adopt many of the anti-BEPS tax treaty rules. Download this article.
Canada Expands Back-to-Back Regime: Examining the Character Substitution Rules
June 19, 2017 - In this article from Tax Notes International, Davies partner Michael Kandev explains Canada’s latest attempt to fight treaty shopping through an expanded back-to-back regime, focusing on the regime’s complex and sometimes mysterious character substitution rules. Download this article.
2017 Federal Budget: Tax Highlights
Mar. 22, 2017 - The Liberal government’s second budget (Budget 2017) comes during a period of exceptional global political and economic uncertainty. Of particular importance from a Canadian economic and tax policy perspective is the uncertainty about how the Trump administration’s agenda will unfold in the coming...
The Lexpert/American Lawyer Guide to the Leading 500 Lawyers in Canada—Corporate Tax
Report on Business/Lexpert Special Edition Canada’s Leading Corporate Lawyers
Lexpert Guide to the Leading US/Canada Cross-Border Corporate Lawyers in Canada—Corporate Tax
The Canadian Legal Lexpert Directory—Corporate Tax (Most Frequently Recommended); Estate and Personal Tax Planning: Estate and Tax Planning
The Best Lawyers in Canada—Tax Law