Epic Games, Inc.
Acted for Epic Games, Inc. in its investment in Toronto-based SideFX, the company behind the Houdini 3D animation software used in video game development as well as for visual effects in film productions.
Partner
Partner
Michael’s clients turn to him for meticulous and innovative tax advice.
Michael provides advice to corporations and individuals 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. He has extensive expertise in international tax issues.
Michael is a frequent speaker at tax conferences in Canada and abroad. He is a contributing editor to the Wolters Kluwer International Tax Journal and is councillor and treasurer of the Canadian branch of the International Fiscal Association.
Partner
Michael’s clients turn to him for meticulous and innovative tax advice.
Michael provides advice to corporations and individuals 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. He has extensive expertise in international tax issues.
Michael is a frequent speaker at tax conferences in Canada and abroad. He is a contributing editor to the Wolters Kluwer International Tax Journal and is councillor and treasurer of the Canadian branch of the International Fiscal Association.
Epic Games, Inc.
Acted for Epic Games, Inc. in its investment in Toronto-based SideFX, the company behind the Houdini 3D animation software used in video game development as well as for visual effects in film productions.
Lantic Inc.
Acted for Lantic Inc. in its strategic collaboration with DouxMatok to deliver a unique sugar reduction solution on cane sugar to food companies in North America.
Desjardins Securities Inc.
Acted for a syndicate of underwriters co-led by Desjardins Securities Inc. and Stifel Nicolaus Canada Inc. in Goodfood Market Corp.'s $40-million bought deal public offering of common shares including the full exercise of the over-allotment option by the underwriters.
Boutique Linus Inc.
Acted for Boutique Linus Inc. which operates Fortnine.ca, a leading Canadian online retailer and distributor in the powersports industry, in a sale of an interest to Novacap.
NDT Global Corporate
Acted as Canadian tax counsel to Ireland-headquartered NDT Global, a leading supplier of ultrasonic pipeline inspection and data analysis, on its sale to Caisse de dépôt et placement du Québec/Novacap-backed Eddyfi Technologies, a Québec-based innovative private test & measurement technology group focused on non-destructive testing (NDT).
Groupe Latécoère
Acting for Groupe Latécoère in its acquisition from Bombardier Inc. and certain of its affiliates of the assets relating to electrical wiring interconnection activities for the production of main and sub-electrical harnesses for commercial and business aviation programs.
Teneo
Acted for Teneo in its acquisition of Hatley Strategy Advisors, a leading strategic communications and corporate advisory firm based in Montréal, Canada.
Esarbee Investments Canada Ltd.
Acted for Esarbee Investments Canada Ltd. in a private placement transaction involving Califia Farms, LLC.
Caisse de dépôt et placement du Québec
Acted for Caisse de dépôt et placement du Québec (Caisse) and CDP Financial Inc. in CDP Financial's establishment and launch of a US$20-billion senior notes program guaranteed by Caisse, including four subsequent offerings by CDP Financial totalling US$8.5 billion in senior notes under the program.
Beanfield Technologies Inc.
Acted for Beanfield Technologies Inc., a portfolio company of Digital Colony, in its acquisition of Openface Inc., the largest independent enterprise fibre solutions provider in Montréal.
Driven Brands Inc.
Acted for Roark Capital-backed Driven Brands Inc. in its acquisition of Clairus Canada Group, a major automotive parts, windshield repair and claims management business based in Québec.
Hasbro, Inc.
Acted for Hasbro, Inc., and its subsidiary Wizards of the Coast in their acquisition of Montréal-based Tuque Games, a video game studio making a Dungeons & Dragons triple-A game.
Digital Colony
Acted for Digital Colony, the global digital infrastructure investment platform of Colony Capital, Inc., in its acquisition (and related bank financing) of Beanfield Technologies Inc., an independent bandwidth infrastructure provider serving the enterprise, carrier and multi-dwelling unit markets in Toronto and Montréal over its owned fibre network.
Nutrien Ltd.
Acted as Canadian tax counsel to Nutrien Ltd. in its acquisition, for a purchase price of over A$468 million by way of a scheme of arrangement under Australian law, of Ruralco Holdings Limited, which is listed on the Australian Securities Exchange (ASX: RHL) and is one of Australia's leading agriservice businesses.
Power Energy Corporation
Acted for Power Energy Corporation in its acquisition of Nautilus Solar Energy, LLC, a leading U.S. solar developer and asset manager, from management and Virgo Investment Group.
Valmet Technologies and Services Inc.
Acted as Canadian counsel to Valmet Technologies and Services Inc. in its acquisition of all the issued and outstanding shares of GL&V Canada Inc., a global provider of technologies and services to the pulp and paper industry.
Nutrien Ltd.
Acted as Canadian tax counsel to Nutrien Ltd. in its acquisition of Actagro, LLC, a leading developer, manufacturer and marketer of environmentally sustainable soil and plant health products and technologies.
GMP Securities L.P.
Acted for a syndicate of underwriters led by GMP Securities L.P. and comprising Desjardins Securities Inc., National Bank Financial Inc., Acumen Capital Finance Partners Limited, Scotia Capital Inc., RBC Dominion Securities Inc., Raymond James Ltd., Canaccord Genuity Corporation and PI Financial Corp. in a bought deal offering of 7,142,857 common shares of Goodfood Market Corp. for gross proceeds to the corporation of approximately $25 million.
Claridge Inc.
Acted for Claridge Inc. in its strategic partnership with Champlain Financial Corporation to support the acquisition of Captain Dan's Seafood by The Champlain Seafood platform.
GAEA Grand Holdings Limited
Acted for GAEA Grand Holdings Limited, a leading global interactive entertainment company, in its investment in Behaviour Interactive Inc.
Interactive Validated Solutions 88 Inc.
Acted for Interactive Validated Solutions 88 Inc. (Pivot 88) in connection with an equity investment by Newtimes Development Ltd.
Nutrien Ltd.
Acted as Canadian tax counsel to Nutrien Ltd. in the sale to SDIC Mining Investment Co. Ltd. of 23,294,614 common shares of Arab Potash Company for gross proceeds of $502 million.
Power Energy Eagle Creek, LLP
Acted for a joint venture of Power Energy Corporation, a subsidiary of Power Corporation of Canada, and Claridge Inc. in the sale of their majority interest in Eagle Creek Renewable Energy, LLC, an operator of 63 hydropower facilities in the United States, representing 216 MW of capacity.
A group of investors
Acted for a group of investors regarding MPX Bioceutical Corporation's issuance, through a wholly owned Luxembourg subsidiary, of US$40 million in secured convertible original issue discount notes.
Nutrien Ltd.
Acted as Canadian tax counsel to Nutrien Ltd. in respect of the sale to Tianqi Lithium Corporation of Nutrien's 62,556,568 "A shares" in the capital of Sociedad Química y Minera de Chile S.A. for consideration of $65 per share in cash, representing a total gross valuation of approximately US$4.07 billion.
Michelin Group
Acted for the Michelin Group in its acquisition of Camso Inc., one of the global leaders in the design, manufacturing and distribution of off-road tires, wheels, tracks and conveyer belts, for a purchase price of US$1.7 billion. Camso has facilities in more than 25 jurisdictions world-wide.
Confidential client
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.
Nutrien Ltd.
Acted 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.
Acted 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.
Claridge Inc.
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 power plant located in Lachute, Québec, that transforms the biogas released at a landfill site into electricity, to Energy Developments (Canada) Inc., a subsidiary of Energy Developments Pty Limited, a member of Australia's DUET group.
Stingray Group Inc.
Acted for Stingray Group Inc. in connection with its acquisition of all the outstanding shares of C Music Entertainment Ltd. (also known as C Music TV).
High-Net-Worth Family
Acted for a high-net-worth family on tax matters related to a reorganization of the family's corporate holdings.
High-Net-Worth Family
Advised a high-net-worth family on tax matters related to acquisition of aircraft.
The Sentient Group
Acted for The Sentient Group in connection with its US$7-million investment in Era Resources Inc. through the purchase of a convertible unsecured note.
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.
Tippmann US Holdco, Inc. (part of the G.I. Sportz Group)
Acted for G.I. Sportz Inc. in connection with the acquisition of Kee Action Sports, a leading manufacturer and distributor of paintball sporting goods, equipment and apparel, based in New Jersey with distribution facilities located across the United States, Canada and the United Kingdom.
Oceanwide Inc.
Acted for Oceanwide Inc., a Montréal based insurance software firm, in connection with the sale of its business to Insurity Inc., a provider of core insurance processing and data integration and analysis solutions, based in Hartford, Connecticut.
Central National-Gottesman Inc.
Acted for Central National-Gottesman Inc., a global distributor of pulp, paper and forestry products, and its subsidiary Spicers Canada ULC in connection with the acquisition of the assets and business of Spicers Canada Limited, a distributor of fine paper, sign and display media, industrial packaging and graphic arts supplies, headquartered in Vaughan, Ontario and with locations across Canada, and the related financing with Bank of America, N.A. (Canada branch), as agent.
Yoplait France SAS
Acted for Yoplait France SAS, the second largest brand in fresh dairy products in the world, in connection with its acquisition of Québec-based Liberté Brand Products from its management and investment firms, Swander Pace Capital LLC and Roynat Capital Inc.
Honeywell International Inc.
Acted for Honeywell International Inc. in connection with the $144-million acquisition of Matrikon Inc., a company specializing in software used in manufacturing operations.
Mill Road Capital, L.P.
Acted for U.S.-based private equity firm Mill Road Capital, L.P. in its successful "white knight" bid for Cossette Inc. for approximately $134 million.
Rossy and Assaly families
Acted for the founders of Dollarama Inc. in connection with the corporation's $300 million initial public offering of common shares.
Alexis Nihon Real Estate Investment Trust
Acted for Alexis Nihon Real Estate Investment Trust in the initial public offering of $85 million of trust units.
Canada’s Fall Economic Statement: Tax Highlights
Dec. 01, 2020 - The Honourable Chrystia Freeland, Deputy Prime Minister of Canada and Minister of Finance, has released the Liberal Party’s first economic statement (Fall Economic Statement) since the start of the global COVID-19 pandemic. A record deficit of over $381 billion is projected for 2020-2021. This...
APFF, 2020 Annual Conference, “International Tax Outlookˮ; Webinar
Oct. 08, 2020
Canada’s Response to International Tax Issues Raised by COVID-19, co-author
July 20, 2020 - Tax Notes International, Vol. 99, No. 3 (Tax Analysts)
Download this article.
Chartered Institute of Taxation, 10th Annual Joint International Tax Conference, “Emerging GAARs in International Tax”; Webinar
July 10, 2020
CRA Provides Relief from International Income Tax Issues Raised by COVID-19 Travel Restrictions
June 30, 2020 - The COVID-19 pandemic has resulted in the imposition of safety measures by governments around the world, including that in Canada, to protect the health of their citizens. Similarly, businesses have imposed safety measures to protect their employees. These measures include restrictions on travel...
Québec Proposes North America’s First IP Box, co-author
June 29, 2020 - Tax Notes International, Vol. 98, No. 13 (Tax Analysts)
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Canadian Appeal Court Rejects Government’s Treaty-Shopping Arguments Against Luxembourg Holding Company, co-author
June 15, 2020 - Tax Notes International, Vol. 98, No. 11 (Tax Analysts)
Download this article.
Evaluating Canada’s Attempt to Reconcile General Transfer Pricing Rules and Specific Antiabuse Provisions, co-author
May 11, 2020 - Tax Notes International, Vol. 98, No. 6 (Tax Analysts)
Download this article.
Obscure Canadian Withholding Tax Rule a Trap for the Unwary, co-author
Mar. 09, 2020 - Tax Notes International, Vol. 97, No. 10 (Tax Analysts)
Download this article.
Chair, International Fiscal Association, US-Canada Joint Meeting, “M&A/Cross Border Structuring – United States to Canada Investment”; Boston, MA
Feb. 26, 2020
Canadian Tax Laws: A Review of 2019 and a Look Ahead to 2020
Jan. 30, 2020 - Each year at this time we look back at some of the more significant income tax developments in Canada affecting domestic and international business over the past year and look ahead to possible Canadian tax developments in the coming year. Review of Canadian Tax Developments in 2019 Tax...
Canada Enacts Multilateral Instrument: What Happens Next?, co-author
July 22, 2019 - Tax Notes International, Vol. 95, No. 4 (Tax Analysts)
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Canada Enacts the OECD-Sponsored Multilateral Instrument
June 26, 2019 - Canada has enacted into law the OECD-sponsored Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The enactment of June 21, 2019 represents the penultimate step in the domestic ratification of the MLI in Canada, which will...
Interpreting the Expression “Arrangement or Transaction” in the Principal Purpose Test of the MLI, co-author
June 01, 2019 - International Tax Newsletter, No. 106 (Wolters Kluwer)
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Moderator, IFA International Tax Conference 2019, “MLI Implementation and OECD Developments”; Montréal, QC
May 14, 2019
2019 Federal Budget: Tax Highlights
Mar. 19, 2019 - Budget 2019 is the last federal budget of the current Liberal government before the upcoming federal election in October 2019. Tax-related measures are intended to advance the government’s stated priority of creating a fair tax system. Proposals include changes to the employee stock option rules,...
Expected Adverse Effects of Proposed U.S. Anti-Hybrid Regulations on Inbound Financing By Canadian MNEx, co-author
Feb. 11, 2019 - Tax Notes International, Vol. 93, No 6 (Tax Analysts)
Download this article.
Canadian and U.S. Tax Laws: A Review of 2018 and a Look Ahead to 2019
Jan. 31, 2019 - In our annual Tax Review and Outlook report, we look back at significant developments in the Canadian and U.S. tax landscapes in 2018 and offer our predictions on what to expect in 2019. Key Canadian Developments in 2018 Budget 2018 scaled back controversial initiative on taxation of passive...
Canadian Tax Laws: A Review of 2018 and a Look Ahead to 2019
Jan. 31, 2019 - 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. Legislative Developments in 2018 Budget 2018 A. ...
Now It’s “Excluded Property”, Now It’s Not, co-author
Dec. 01, 2018 - International Tax Newsletter, No. 103 (Wolters Kluwer)
Download this article.
The Tax Court of Canada Strikes Offshore eBank in Loblaw, co-author
Oct. 29, 2018 - Tax Notes International, Vol. 92, No.5 (Tax Analysts)
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Taxpayer Wins Treaty Shopping Challenge in Alta Energy Luxembourg, co-author
Sept. 14, 2018 - Tax Management International Journal (The Bureau of National Affairs, Inc.)
Download this article.
With Tax Reform Sweeping the Globe, What About Canada?
Aug. 13, 2018 - Tax Notes International, Vol. 91, No.7 (Tax Analysts)
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Michael Kandev Speaks to AFP on Repercussions of U.S. Corporate Tax Reform
Aug. 09, 2018 - Davies partner Michael Kandev spoke recently to the Association for Financial Professionals about the impact of significantly reduced U.S. corporate tax rates on global businesses. Michael believes it would be unwise for companies to make rash moves based on U.S. tax reform, and he doesn’t...
IFA International Tax Conference 2018, “Recent Developments of Interest”; Calgary, AB
May 16, 2018
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...
Université de Montréal , Les Rendez-vous juridiques 2017-1018, “The Morneau Reform and Fairness in the Tax System: From Theory to Practice”; Montréal, QC
Feb. 21, 2018
Update: Impact of U.S. Tax Reform on Canadian Multinationals, co-author
Feb. 01, 2018 - International Tax Newsletter, No. 98 (Wolters Kluwer)
Download this article.
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 2017 As we...
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...
Impact of U.S. Tax Reform on Canadian Multinationals, co-author
Dec. 01, 2017 - International Tax Newsletter, No. 97 (Wolters Kluwer)
Download this article.
Canada Persists With Plan to Punish Private Corporate Passive Reinvestment, co-author
Oct. 30, 2017 - Tax Notes International, Vol. 88, No. 5 (Tax Analysts)
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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...
Canadian and U.S. Tax Laws: A Review of 2016 and a Look Ahead to 2017
Jan. 13, 2017 - The year 2016 was eventful from a Canadian tax perspective, with the current Liberal government introducing its first federal budget and important judicial developments that included two decisions in tax cases by the Supreme Court of Canada. Conversely, while U.S. tax developments in 2016 were...
How Is BEPS Reflected in Canada’s Newest Treaties?
Dec. 12, 2016 - In this article published in Tax Notes International, the authors examine the extent to which Canada’s new treaties with Taiwan and Israel reflect its involvement and concern. Download this article.
BEPS Cash Box Inconsistent with Canadian Tax Rules
Oct. 03, 2016 - Originally published in Canadian Tax Highlights, this article examines the BEPS project’s new transfer-pricing notion of “cash box,” which appears to be inconsistent both with commercial reality and with longstanding Canadian outbound international tax policy. Download this article.
The Federal Court of Appeal Permits Use of Mark-To-Market Tax Accounting
June 24, 2016 - The Federal Court of Appeal has held in the Kruger Inc. v. Canada decision published yesterday, that Kruger Inc. was entitled to use the mark-to-market method in computing its income for federal income tax purposes. As a result, for income tax purposes it was entitled to recognize an...
BEPS: Canada Takes First BEPS Steps
May 24, 2016 - Originally published in Tax Notes International, this article examines provisions in Canada’s 2016 budget inspired by the OECD’s final reports on its base erosion and profit shifting project. Download this article.
Apr. 01, 2016 - As part of Canada’s Federal Budget that was presented on March 22, 2016, Finance Minister Bill Morneau announced the repeal, effective January 1, 2017, of the existing eligible capital property ( ECP ) tax regime and its merger into the existing depreciable capital property rules. While the new...
2016 Federal Budget: Tax Highlights
Mar. 22, 2016 - The new Liberal government ’ s first budget (Budget 2016) has been the subject of anticipation and speculation, much of it apprehensive. Unusually, Budget 2016 is noteworthy for what it does not contain. Budget 2016 does not introduce changes to increase the tax rate on employee stock option...
Canadian and U.S. Tax Laws: A Review of 2015 and a Look Ahead to 2016
Jan. 20, 2016 - Each year at this time, we offer a look back at some of the more significant business and international tax developments in Canada and the United States over the past year and a look ahead to possible Canadian and U.S. tax developments in the coming year. Canadian Tax Review and Outlook ...
BEPS: A Spent Force or Radical Change?
Dec. 21, 2015 - Originally published in Tax Notes International, this article examines from an overall and a Canadian perspective whether the OECD’s initiative against base erosion and profit shifting (BEPS) has turned out to be a spent force or if, instead, it will spawn radical change in the behaviour...
Interest Deductibility in Canada: What’s the Fuss?
July 27, 2015 - This article deals with the manner in which Canada has complicated, and rendered controversial, what in most other countries is straightforward — the deductibility of business-related interest expense. The reasons to write about it are threefold: the almost-concurrent issuance of the Canada...
2015 Federal Budget: Tax Highlights
Apr. 21, 2015 - As has been widely predicted, today’s federal budget (Budget 2015) delivered a handful of tax “ goodies ” in the lead-up to the coming election. It also includes a number of important proposed changes to the corporate tax rules. They are noteworthy, although not as extensive as the corporate tax...
Chambers Canada: Canada’s Leading Lawyers for Business—Tax
The Lexpert/American Lawyer Guide to the Leading 500 Lawyers in Canada—Corporate Tax
Lexpert Special Edition: Finance and M&A
Lexpert Guide to US/Canada Cross-Border Lawyers in Canada—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
Who’s Who Legal: Canada—Corporate Tax; Who’s Who Legal: Corporate Tax—Advisory
Québec, 2003
Ontario, 2002
Canadian Institute of Chartered Accountants, In-Depth Tax Course
Universiteit Leiden, LLM (International Taxation) (Cum Laude), 2006
McGill University, BCL/LLB (with Great Distinction), 2001
Association de planification fiscale et financière
Canadian Tax Foundation
International Fiscal Association
International Fiscal Association, Canada Council, councillor and treasurer
Wolters and Kluwer International Tax Journal, contributing editor
Michael has lectured on taxation at McGill University and Université de Montréal.
Michael’s clients turn to him for meticulous and innovative tax advice.
Michael provides advice to corporations and individuals 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. He has extensive expertise in international tax issues.
Michael is a frequent speaker at tax conferences in Canada and abroad. He is a contributing editor to the Wolters Kluwer International Tax Journal and is councillor and treasurer of the Canadian branch of the International Fiscal Association.
Epic Games, Inc.
Acted for Epic Games, Inc. in its investment in Toronto-based SideFX, the company behind the Houdini 3D animation software used in video game development as well as for visual effects in film productions.
Lantic Inc.
Acted for Lantic Inc. in its strategic collaboration with DouxMatok to deliver a unique sugar reduction solution on cane sugar to food companies in North America.
Desjardins Securities Inc.
Acted for a syndicate of underwriters co-led by Desjardins Securities Inc. and Stifel Nicolaus Canada Inc. in Goodfood Market Corp.'s $40-million bought deal public offering of common shares including the full exercise of the over-allotment option by the underwriters.
Boutique Linus Inc.
Acted for Boutique Linus Inc. which operates Fortnine.ca, a leading Canadian online retailer and distributor in the powersports industry, in a sale of an interest to Novacap.
NDT Global Corporate
Acted as Canadian tax counsel to Ireland-headquartered NDT Global, a leading supplier of ultrasonic pipeline inspection and data analysis, on its sale to Caisse de dépôt et placement du Québec/Novacap-backed Eddyfi Technologies, a Québec-based innovative private test & measurement technology group focused on non-destructive testing (NDT).
Groupe Latécoère
Acting for Groupe Latécoère in its acquisition from Bombardier Inc. and certain of its affiliates of the assets relating to electrical wiring interconnection activities for the production of main and sub-electrical harnesses for commercial and business aviation programs.
Teneo
Acted for Teneo in its acquisition of Hatley Strategy Advisors, a leading strategic communications and corporate advisory firm based in Montréal, Canada.
Esarbee Investments Canada Ltd.
Acted for Esarbee Investments Canada Ltd. in a private placement transaction involving Califia Farms, LLC.
Caisse de dépôt et placement du Québec
Acted for Caisse de dépôt et placement du Québec (Caisse) and CDP Financial Inc. in CDP Financial's establishment and launch of a US$20-billion senior notes program guaranteed by Caisse, including four subsequent offerings by CDP Financial totalling US$8.5 billion in senior notes under the program.
Beanfield Technologies Inc.
Acted for Beanfield Technologies Inc., a portfolio company of Digital Colony, in its acquisition of Openface Inc., the largest independent enterprise fibre solutions provider in Montréal.
Driven Brands Inc.
Acted for Roark Capital-backed Driven Brands Inc. in its acquisition of Clairus Canada Group, a major automotive parts, windshield repair and claims management business based in Québec.
Hasbro, Inc.
Acted for Hasbro, Inc., and its subsidiary Wizards of the Coast in their acquisition of Montréal-based Tuque Games, a video game studio making a Dungeons & Dragons triple-A game.
Digital Colony
Acted for Digital Colony, the global digital infrastructure investment platform of Colony Capital, Inc., in its acquisition (and related bank financing) of Beanfield Technologies Inc., an independent bandwidth infrastructure provider serving the enterprise, carrier and multi-dwelling unit markets in Toronto and Montréal over its owned fibre network.
Nutrien Ltd.
Acted as Canadian tax counsel to Nutrien Ltd. in its acquisition, for a purchase price of over A$468 million by way of a scheme of arrangement under Australian law, of Ruralco Holdings Limited, which is listed on the Australian Securities Exchange (ASX: RHL) and is one of Australia's leading agriservice businesses.
Power Energy Corporation
Acted for Power Energy Corporation in its acquisition of Nautilus Solar Energy, LLC, a leading U.S. solar developer and asset manager, from management and Virgo Investment Group.
Valmet Technologies and Services Inc.
Acted as Canadian counsel to Valmet Technologies and Services Inc. in its acquisition of all the issued and outstanding shares of GL&V Canada Inc., a global provider of technologies and services to the pulp and paper industry.
Nutrien Ltd.
Acted as Canadian tax counsel to Nutrien Ltd. in its acquisition of Actagro, LLC, a leading developer, manufacturer and marketer of environmentally sustainable soil and plant health products and technologies.
GMP Securities L.P.
Acted for a syndicate of underwriters led by GMP Securities L.P. and comprising Desjardins Securities Inc., National Bank Financial Inc., Acumen Capital Finance Partners Limited, Scotia Capital Inc., RBC Dominion Securities Inc., Raymond James Ltd., Canaccord Genuity Corporation and PI Financial Corp. in a bought deal offering of 7,142,857 common shares of Goodfood Market Corp. for gross proceeds to the corporation of approximately $25 million.
Claridge Inc.
Acted for Claridge Inc. in its strategic partnership with Champlain Financial Corporation to support the acquisition of Captain Dan's Seafood by The Champlain Seafood platform.
GAEA Grand Holdings Limited
Acted for GAEA Grand Holdings Limited, a leading global interactive entertainment company, in its investment in Behaviour Interactive Inc.
Interactive Validated Solutions 88 Inc.
Acted for Interactive Validated Solutions 88 Inc. (Pivot 88) in connection with an equity investment by Newtimes Development Ltd.
Nutrien Ltd.
Acted as Canadian tax counsel to Nutrien Ltd. in the sale to SDIC Mining Investment Co. Ltd. of 23,294,614 common shares of Arab Potash Company for gross proceeds of $502 million.
Power Energy Eagle Creek, LLP
Acted for a joint venture of Power Energy Corporation, a subsidiary of Power Corporation of Canada, and Claridge Inc. in the sale of their majority interest in Eagle Creek Renewable Energy, LLC, an operator of 63 hydropower facilities in the United States, representing 216 MW of capacity.
A group of investors
Acted for a group of investors regarding MPX Bioceutical Corporation's issuance, through a wholly owned Luxembourg subsidiary, of US$40 million in secured convertible original issue discount notes.
Nutrien Ltd.
Acted as Canadian tax counsel to Nutrien Ltd. in respect of the sale to Tianqi Lithium Corporation of Nutrien's 62,556,568 "A shares" in the capital of Sociedad Química y Minera de Chile S.A. for consideration of $65 per share in cash, representing a total gross valuation of approximately US$4.07 billion.
Michelin Group
Acted for the Michelin Group in its acquisition of Camso Inc., one of the global leaders in the design, manufacturing and distribution of off-road tires, wheels, tracks and conveyer belts, for a purchase price of US$1.7 billion. Camso has facilities in more than 25 jurisdictions world-wide.
Confidential client
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.
Nutrien Ltd.
Acted 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.
Acted 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.
Claridge Inc.
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 power plant located in Lachute, Québec, that transforms the biogas released at a landfill site into electricity, to Energy Developments (Canada) Inc., a subsidiary of Energy Developments Pty Limited, a member of Australia's DUET group.
Stingray Group Inc.
Acted for Stingray Group Inc. in connection with its acquisition of all the outstanding shares of C Music Entertainment Ltd. (also known as C Music TV).
High-Net-Worth Family
Acted for a high-net-worth family on tax matters related to a reorganization of the family's corporate holdings.
High-Net-Worth Family
Advised a high-net-worth family on tax matters related to acquisition of aircraft.
The Sentient Group
Acted for The Sentient Group in connection with its US$7-million investment in Era Resources Inc. through the purchase of a convertible unsecured note.
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.
Tippmann US Holdco, Inc. (part of the G.I. Sportz Group)
Acted for G.I. Sportz Inc. in connection with the acquisition of Kee Action Sports, a leading manufacturer and distributor of paintball sporting goods, equipment and apparel, based in New Jersey with distribution facilities located across the United States, Canada and the United Kingdom.
Oceanwide Inc.
Acted for Oceanwide Inc., a Montréal based insurance software firm, in connection with the sale of its business to Insurity Inc., a provider of core insurance processing and data integration and analysis solutions, based in Hartford, Connecticut.
Central National-Gottesman Inc.
Acted for Central National-Gottesman Inc., a global distributor of pulp, paper and forestry products, and its subsidiary Spicers Canada ULC in connection with the acquisition of the assets and business of Spicers Canada Limited, a distributor of fine paper, sign and display media, industrial packaging and graphic arts supplies, headquartered in Vaughan, Ontario and with locations across Canada, and the related financing with Bank of America, N.A. (Canada branch), as agent.
Yoplait France SAS
Acted for Yoplait France SAS, the second largest brand in fresh dairy products in the world, in connection with its acquisition of Québec-based Liberté Brand Products from its management and investment firms, Swander Pace Capital LLC and Roynat Capital Inc.
Honeywell International Inc.
Acted for Honeywell International Inc. in connection with the $144-million acquisition of Matrikon Inc., a company specializing in software used in manufacturing operations.
Mill Road Capital, L.P.
Acted for U.S.-based private equity firm Mill Road Capital, L.P. in its successful "white knight" bid for Cossette Inc. for approximately $134 million.
Rossy and Assaly families
Acted for the founders of Dollarama Inc. in connection with the corporation's $300 million initial public offering of common shares.
Alexis Nihon Real Estate Investment Trust
Acted for Alexis Nihon Real Estate Investment Trust in the initial public offering of $85 million of trust units.
Canada’s Fall Economic Statement: Tax Highlights
Dec. 01, 2020 - The Honourable Chrystia Freeland, Deputy Prime Minister of Canada and Minister of Finance, has released the Liberal Party’s first economic statement (Fall Economic Statement) since the start of the global COVID-19 pandemic. A record deficit of over $381 billion is projected for 2020-2021. This...
APFF, 2020 Annual Conference, “International Tax Outlookˮ; Webinar
Oct. 08, 2020
Canada’s Response to International Tax Issues Raised by COVID-19, co-author
July 20, 2020 - Tax Notes International, Vol. 99, No. 3 (Tax Analysts)
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Chartered Institute of Taxation, 10th Annual Joint International Tax Conference, “Emerging GAARs in International Tax”; Webinar
July 10, 2020
CRA Provides Relief from International Income Tax Issues Raised by COVID-19 Travel Restrictions
June 30, 2020 - The COVID-19 pandemic has resulted in the imposition of safety measures by governments around the world, including that in Canada, to protect the health of their citizens. Similarly, businesses have imposed safety measures to protect their employees. These measures include restrictions on travel...
Québec Proposes North America’s First IP Box, co-author
June 29, 2020 - Tax Notes International, Vol. 98, No. 13 (Tax Analysts)
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Canadian Appeal Court Rejects Government’s Treaty-Shopping Arguments Against Luxembourg Holding Company, co-author
June 15, 2020 - Tax Notes International, Vol. 98, No. 11 (Tax Analysts)
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Evaluating Canada’s Attempt to Reconcile General Transfer Pricing Rules and Specific Antiabuse Provisions, co-author
May 11, 2020 - Tax Notes International, Vol. 98, No. 6 (Tax Analysts)
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Obscure Canadian Withholding Tax Rule a Trap for the Unwary, co-author
Mar. 09, 2020 - Tax Notes International, Vol. 97, No. 10 (Tax Analysts)
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Chair, International Fiscal Association, US-Canada Joint Meeting, “M&A/Cross Border Structuring – United States to Canada Investment”; Boston, MA
Feb. 26, 2020
Canadian Tax Laws: A Review of 2019 and a Look Ahead to 2020
Jan. 30, 2020 - Each year at this time we look back at some of the more significant income tax developments in Canada affecting domestic and international business over the past year and look ahead to possible Canadian tax developments in the coming year. Review of Canadian Tax Developments in 2019 Tax...
Canada Enacts Multilateral Instrument: What Happens Next?, co-author
July 22, 2019 - Tax Notes International, Vol. 95, No. 4 (Tax Analysts)
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Canada Enacts the OECD-Sponsored Multilateral Instrument
June 26, 2019 - Canada has enacted into law the OECD-sponsored Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The enactment of June 21, 2019 represents the penultimate step in the domestic ratification of the MLI in Canada, which will...
Interpreting the Expression “Arrangement or Transaction” in the Principal Purpose Test of the MLI, co-author
June 01, 2019 - International Tax Newsletter, No. 106 (Wolters Kluwer)
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Moderator, IFA International Tax Conference 2019, “MLI Implementation and OECD Developments”; Montréal, QC
May 14, 2019
2019 Federal Budget: Tax Highlights
Mar. 19, 2019 - Budget 2019 is the last federal budget of the current Liberal government before the upcoming federal election in October 2019. Tax-related measures are intended to advance the government’s stated priority of creating a fair tax system. Proposals include changes to the employee stock option rules,...
Expected Adverse Effects of Proposed U.S. Anti-Hybrid Regulations on Inbound Financing By Canadian MNEx, co-author
Feb. 11, 2019 - Tax Notes International, Vol. 93, No 6 (Tax Analysts)
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Canadian and U.S. Tax Laws: A Review of 2018 and a Look Ahead to 2019
Jan. 31, 2019 - In our annual Tax Review and Outlook report, we look back at significant developments in the Canadian and U.S. tax landscapes in 2018 and offer our predictions on what to expect in 2019. Key Canadian Developments in 2018 Budget 2018 scaled back controversial initiative on taxation of passive...
Canadian Tax Laws: A Review of 2018 and a Look Ahead to 2019
Jan. 31, 2019 - 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. Legislative Developments in 2018 Budget 2018 A. ...
Now It’s “Excluded Property”, Now It’s Not, co-author
Dec. 01, 2018 - International Tax Newsletter, No. 103 (Wolters Kluwer)
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The Tax Court of Canada Strikes Offshore eBank in Loblaw, co-author
Oct. 29, 2018 - Tax Notes International, Vol. 92, No.5 (Tax Analysts)
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Taxpayer Wins Treaty Shopping Challenge in Alta Energy Luxembourg, co-author
Sept. 14, 2018 - Tax Management International Journal (The Bureau of National Affairs, Inc.)
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With Tax Reform Sweeping the Globe, What About Canada?
Aug. 13, 2018 - Tax Notes International, Vol. 91, No.7 (Tax Analysts)
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Michael Kandev Speaks to AFP on Repercussions of U.S. Corporate Tax Reform
Aug. 09, 2018 - Davies partner Michael Kandev spoke recently to the Association for Financial Professionals about the impact of significantly reduced U.S. corporate tax rates on global businesses. Michael believes it would be unwise for companies to make rash moves based on U.S. tax reform, and he doesn’t...
IFA International Tax Conference 2018, “Recent Developments of Interest”; Calgary, AB
May 16, 2018
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...
Université de Montréal , Les Rendez-vous juridiques 2017-1018, “The Morneau Reform and Fairness in the Tax System: From Theory to Practice”; Montréal, QC
Feb. 21, 2018
Update: Impact of U.S. Tax Reform on Canadian Multinationals, co-author
Feb. 01, 2018 - International Tax Newsletter, No. 98 (Wolters Kluwer)
Download this article.
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 2017 As we...
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...
Impact of U.S. Tax Reform on Canadian Multinationals, co-author
Dec. 01, 2017 - International Tax Newsletter, No. 97 (Wolters Kluwer)
Download this article.
Canada Persists With Plan to Punish Private Corporate Passive Reinvestment, co-author
Oct. 30, 2017 - Tax Notes International, Vol. 88, No. 5 (Tax Analysts)
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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...
Canadian and U.S. Tax Laws: A Review of 2016 and a Look Ahead to 2017
Jan. 13, 2017 - The year 2016 was eventful from a Canadian tax perspective, with the current Liberal government introducing its first federal budget and important judicial developments that included two decisions in tax cases by the Supreme Court of Canada. Conversely, while U.S. tax developments in 2016 were...
How Is BEPS Reflected in Canada’s Newest Treaties?
Dec. 12, 2016 - In this article published in Tax Notes International, the authors examine the extent to which Canada’s new treaties with Taiwan and Israel reflect its involvement and concern. Download this article.
BEPS Cash Box Inconsistent with Canadian Tax Rules
Oct. 03, 2016 - Originally published in Canadian Tax Highlights, this article examines the BEPS project’s new transfer-pricing notion of “cash box,” which appears to be inconsistent both with commercial reality and with longstanding Canadian outbound international tax policy. Download this article.
The Federal Court of Appeal Permits Use of Mark-To-Market Tax Accounting
June 24, 2016 - The Federal Court of Appeal has held in the Kruger Inc. v. Canada decision published yesterday, that Kruger Inc. was entitled to use the mark-to-market method in computing its income for federal income tax purposes. As a result, for income tax purposes it was entitled to recognize an...
BEPS: Canada Takes First BEPS Steps
May 24, 2016 - Originally published in Tax Notes International, this article examines provisions in Canada’s 2016 budget inspired by the OECD’s final reports on its base erosion and profit shifting project. Download this article.
Apr. 01, 2016 - As part of Canada’s Federal Budget that was presented on March 22, 2016, Finance Minister Bill Morneau announced the repeal, effective January 1, 2017, of the existing eligible capital property ( ECP ) tax regime and its merger into the existing depreciable capital property rules. While the new...
2016 Federal Budget: Tax Highlights
Mar. 22, 2016 - The new Liberal government ’ s first budget (Budget 2016) has been the subject of anticipation and speculation, much of it apprehensive. Unusually, Budget 2016 is noteworthy for what it does not contain. Budget 2016 does not introduce changes to increase the tax rate on employee stock option...
Canadian and U.S. Tax Laws: A Review of 2015 and a Look Ahead to 2016
Jan. 20, 2016 - Each year at this time, we offer a look back at some of the more significant business and international tax developments in Canada and the United States over the past year and a look ahead to possible Canadian and U.S. tax developments in the coming year. Canadian Tax Review and Outlook ...
BEPS: A Spent Force or Radical Change?
Dec. 21, 2015 - Originally published in Tax Notes International, this article examines from an overall and a Canadian perspective whether the OECD’s initiative against base erosion and profit shifting (BEPS) has turned out to be a spent force or if, instead, it will spawn radical change in the behaviour...
Interest Deductibility in Canada: What’s the Fuss?
July 27, 2015 - This article deals with the manner in which Canada has complicated, and rendered controversial, what in most other countries is straightforward — the deductibility of business-related interest expense. The reasons to write about it are threefold: the almost-concurrent issuance of the Canada...
2015 Federal Budget: Tax Highlights
Apr. 21, 2015 - As has been widely predicted, today’s federal budget (Budget 2015) delivered a handful of tax “ goodies ” in the lead-up to the coming election. It also includes a number of important proposed changes to the corporate tax rules. They are noteworthy, although not as extensive as the corporate tax...
Chambers Canada: Canada’s Leading Lawyers for Business—Tax
The Lexpert/American Lawyer Guide to the Leading 500 Lawyers in Canada—Corporate Tax
Lexpert Special Edition: Finance and M&A
Lexpert Guide to US/Canada Cross-Border Lawyers in Canada—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
Who’s Who Legal: Canada—Corporate Tax; Who’s Who Legal: Corporate Tax—Advisory
Québec, 2003
Ontario, 2002
Canadian Institute of Chartered Accountants, In-Depth Tax Course
Universiteit Leiden, LLM (International Taxation) (Cum Laude), 2006
McGill University, BCL/LLB (with Great Distinction), 2001
Association de planification fiscale et financière
Canadian Tax Foundation
International Fiscal Association
International Fiscal Association, Canada Council, councillor and treasurer
Wolters and Kluwer International Tax Journal, contributing editor
Michael has lectured on taxation at McGill University and Université de Montréal.
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