Michael N. Kandev

Partner

Michael Kandev

Michael N. Kandev

Partner

Bar Admissions
  • Québec, 2003
    Ontario, 2002

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.

Michael N. Kandev

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.

Viking Global Investors LP

Acted for funds affiliated with Viking Global Investors LP in connection with Valsoft Corporation Inc.'s note issuance in an initial aggregate amount of US$170-million to Coatue Management and funds affiliated with Viking Global Investors LP.

Mason Resources Inc.

Acted for Mason Graphite Inc. with the sale of the Lac Guéret Property, targeted for the development of graphite at the Uatnan Mining Project, to Nouveau Monde Graphite Inc. in consideration of 6,208,210 common shares of Nouveau Monde Graphite Inc. 

Umicore SA

Acted for Umicore SA/NV, a circular materials technology company headquartered in Belgium, in the development and construction of a first-of-its kind EV battery materials manufacturing plant in Loyalist Township, Ontario, that will be 100% fuelled by renewable energy from the start of production.

Interactive Validated Solutions 88 Inc.

Acted for the shareholders, including Desjardins Capital, Anges Québec capital and a large group of angel investors, of Interactive Validated Solutions 88 Inc., a company specializing in SaaS quality, compliance and traceability solutions, in its sale to TradeBeyond, a Hong Kong based leading supply chain platform.

Integrated Media Company

Acted for Integrated Media Company, a TPG platform dedicated to the new media ecosystem, in its C$147.5-million acquisition of Toon Boom Animation Inc., an Emmy® Award-winning Montreal-based animation software company, from Nelvana Limited, a subsidiary of Corus Entertainment Inc.

Sustana

Acted for Sustana, a portfolio company of Blackstone, in its acquisition of Hanna Paper, a high-grade paper recycling company.

Mondi plc

Acted for Mondi plc, a global leader in the production of sustainable packaging and paper, in its acquisition of the Hinton Pulp mill from West Fraser Timber Co. Ltd. (West Fraser) and its long-term partnership with West Fraser to access local, high-quality fibre from well-established wood basket, as well as with Mondi plc’s plans to invest €400 million in the expansion of Hinton.

Industrial and Financial Systems AB

Acted for Industrial and Financial Systems AB in its acquisition of Poka Inc., a Québec-based provider of connected worker platform software.

Burgundy Diamond Mines Limited

Acted for Burgundy Diamond Mines Limited (BDM) in its US$136-million acquisition of Arctic Canadian Diamond Company Limited, including the world-class Ekati Diamond Mine in Canada’s Northwest Territories, and Arctic Canadian Diamond Marketing N.V. Upon closing, BDM became one of the largest listed diamond companies globally.

American Holt, LLC, a portfolio company of Arcline Investment Management

Acted for American Holt, LLC, a portfolio company of Arcline Investment Management, in its acquisition of DMA Solution Inc., a leading engineering company for solutions in the manufacturing of high performance products for the PET plastic container and beverage industries.

Mountaingate Capital Management II, L.P.

Acted for Mountaingate Capital Management II, L.P. in its strategic investment in Bond Brand Loyalty Group, a leading marketing, customer experience and loyalty software management group.

ShockWave Medical, Inc.

Acted as Canadian counsel to Nasdaq-listed Shockwave Medical, Inc., in its acquisition of Nasdaq- and TSX-listed British Columbia–based Neovasc Inc., for a total transaction value of up to US$147 million consisting of a purchase price per share of cash and a contingent value right.

Velan Inc.

Acted for Velan Inc., a global leading manufacturer of industrial valves, in its $329-million all-cash sale and privatization by way of plan of arrangement by Flowserve Corporation, one of the world’s leading providers of fluid motion and control products and services.

WideOrbit Inc.

Acted for WideOrbit, Inc., a California-based media vertical software provider, in its sale to Constellation Software Inc. and its subsidiary Lumine Group Inc., and the related spin-out of the combined Lumine Group Inc. as a new public company listed on the TSX-V.

Cordis-X

Acted for Cordis-X, the lead investor in the C$34-million Series A funding round by Puzzle Medical Devices Inc., a medical device company specializing in the development of a minimally invasive long-term hemodynamic transcatheter pump.

Smile CDR Inc.

Acted for Smile CDR Inc. (doing business as Smile Digital Health), a leading FHIR® health data fabric (HDF) and exchange solutions provider, in its approximately $30-million Series B funding round led by existing investors.

Outfront Media Inc.

Acting as Canadian counsel to OUTFRONT Media Inc. in the C$410-million sale of its Canadian business to Bell Media, a wholly-owned subsidiary of BCE.

EcoPro BM

Acting for Korea-based EcoPro BM in its C$1.2-billion joint venture with Ford and SK On to build a cathode manufacturing facility to produce electric vehicle (EVs) battery materials in Bécancour, Quebec.

Interfor Corporation

Acted for Interfor Corporation in its acquisition for over C$325-million of 100% of the equity interests of Kilmer Group-backed Chaleur Forest Products entities.

Claridge Inc.

Acted for Claridge Food Group in its C$40-million investment in WeCook Meals, the leading ready-to-eat food processor in Québec and Ontario.

Viking Global Investors LP

Acted for funds affiliated with Viking Global Investors LP in their acquisition of a minority stake in Valsoft Corporation Inc., whose business involves the acquisition and growth of vertical software businesses that provide mission-critical solutions to their clients.

Claridge Inc.

Acted for Claridge Inc. in its partnership with Investissement Québec and the Fonds de solidarité FTQ to create an investment vehicle to support Québec food processing companies that show significant growth potential. 

Interfor Corporation

Acted for Interfor Corporation in its $490-million acquisition of 100% of the equity interests of Kelso & Company-backed EACOM Timber Corporation.

Enbridge Inc.

Acted for Enbridge Inc. in the sale of its minority ownership interest in Noverco Inc. to Trencap L.P. for $1.14 billion.

Blackstone Tactical Opportunities

Acted as Canadian counsel to funds managed by Blackstone Tactical Opportunities in their acquisition (and related financing) of H.I.G. Capital-backed Sustana Group, a Wisconsin and Quebec-based manufacturer of premium, sustainable recycled fiber, paper, and packaging products.

Sobeys Inc.

Acted for Sobeys Inc. in the acquisition of a majority interest in Ricardo Media Inc. and in connection with the related shareholders, use of intellectual property and employment arrangements.

Leaseweb Global B.V.

Acted for Leaseweb Global B.V., a leading hosting and cloud services company, in its acquisition of all of the issued and outstanding shares of iWeb Technologies Inc., a subsidiary of Internap Holding LLC and one of Canada's foremost providers of cloud services and server hosting.

Waste Management Inc.

Acted as Canadian counsel to Waste Management Inc., one of the leading residential waste and recycling companies in North America, in its sale of certain assets in Canada to GFL Environmental Inc.

SESAC

Acted as Canadian counsel to SESAC, a portfolio company of Blackstone, in its US$385-million acquisition of Entertainment One Music (eOne) from Hasbro, Inc.

Sequoia Capital

Acted as Canadian counsel to Sequoia Capital in its minority investment in SSENSE, a Montréal-based fashion e-commerce retailer, giving SSENSE a post-money enterprise value of over $5 billion. 

Ceská zbrojovka Defense SE

Acted as Canadian counsel for Ceská zbrojovka Group SE (CZG), a firearms manufacturer based in the Czech Republic, in its acquisition of 100% of the outstanding equity interest in Colt Holding Company LLC, the parent company of the storied U.S. firearms manufacturer Colt's Manufacturing Company LLC, as well as its Canadian subsidiary, Colt Canada Corporation.

Lantic Inc.

Acted for Lantic Inc. in its $100-million offering of 3.49% senior guaranteed notes due April 30, 2031.

Epic Games, Inc.

Acted for Epic Games, Inc., in its acquisition of Montréal-based ArtStation, an online marketplace and industry hub for digital artists.

Groupe Latécoère

Acted for Groupe Latécoère, a portfolio company of Searchlight Capital Partners, 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.

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.

Claridge Inc.

Acted for Claridge Inc. in the formation and fundraising of Claridge Israel II L.P. in partnership with the Caisse de dépôt et placement du Québec. Claridge Israel II L.P. is a private equity fund that makes growth investments in Israeli-related technology or technology-enabled companies. 

Esarbee Investments Canada Ltd.

Acted for Esarbee Investments Canada Ltd. in a private placement transaction involving Califia Farms, LLC.

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).

Teneo

Acted for Teneo in its acquisition of Hatley Strategy Advisors, a leading strategic communications and corporate advisory firm based in Montréal, Canada.

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 Metroconnect

Acted for Beanfield Metroconnect, a portfolio company of DigitalBridge, 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.

DigitalBridge

Acted for DigitalBridge in its acquisition (and related bank financing) of Beanfield Metroconnect, an independent bandwidth infrastructure provider serving the enterprise, carrier and multi-dwelling unit markets in Toronto and Montréal over its owned fibre network.

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.

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.

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.

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.

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.

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.

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.

Interactive Validated Solutions 88 Inc.

Acted for Interactive Validated Solutions 88 Inc. (Pivot 88) in connection with an equity investment by Newtimes Development Ltd.

GAEA Grand Holdings Limited

Acted for GAEA Grand Holdings Limited, a leading global interactive entertainment company, in its investment in Behaviour Interactive Inc.

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.

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.

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.

The Sentient Group

Acted for The Sentient Group in the going-private transaction of Era Resources Inc. effected through a plan of arrangement.

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).

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.

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.

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.

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.

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.

Vision 7 International ULC

Acted for Vision 7 International ULC, a fully integrated marketing communications company, whose two major brands include Canadian marketing communication agency leader Cossette and the international PR firm Citizen Relations, in connection with its acquisition by BlueFocus Communication Group Co., Ltd., the No. 1 integrated communication and marketing services group in China.

Marlin Equity Partners

Acted as Canadian counsel to global investment firm Marlin Equity Partners in connection with its acquisition of the Arcserve division from CA Technologies. Arcserve is a leading global provider of data protection software solutions with offices in 30 countries.

Groupe Trans-Inter Inc.

Acted for the GTI Group, a Montréal-based provider of specialty transport solutions, in connection with an investment by Novacap.

The Sentient Group

Acted for The Sentient Group in connection with the acquisition of Rio Madeira Comércio Importaçao e Exportaçao de Minérios, a Brazilian company operating a manganese mine. In relation to this acquisition, Sentient executed a binding term sheet with Cancana Resources Corp. whereby and pursuant to which Sentient acquired shares, warrants and convertible debentures of Cancana and the latter will subscribe for 50% of the quotas of Rio Madeira.

G.I. Sportz Inc.

Acted for G.I. Sportz Inc. in connection with the acquisition of Tippmann Sports, LLC, a leading manufacturer and distributor of markers and goggles for the paintball, airsoft and laser tag industries.

Morgan Stanley US, Investing Division

Acted for MSG Lac Mirabel, SEC, a joint venture between Morgan Stanley Real Estate and Gordon Group Holdings, LLC, in connection with the sale to Simon Property Group Inc., Calloway Real Estate Investment Trust and SmartCentres, of a portion of the Lac Mirabel site, for the development of a Premium Outlet Centre, Phase I of which will be comprised of 350,000 square feet of gross leasable area and 80 stores.

Alimentation Couche-Tard Inc.

Acted for Alimentation Couche-Tard Inc. in connection with its offering, on a bought deal basis, of 7,302,500 Class B subordinate voting shares at a price of $47.25 per share for gross proceeds of $345,043,125. The offering is made by a syndicate of underwriters co-led by National Bank Financial Inc., Scotia Capital Inc., UBS Securities Canada Inc. and HSBC Securities (Canada) Inc.

Masonite International Corporation

Acted for Masonite International Corporation in connection with its acquisition, through a wholly-owned subsidiary, of all of the capital stock of the Québec-based corporation, Lemieux Doors Inc., known for its broad range of high quality panel and French wood doors and its market leading service proposition.

Confidential Client

Acting before the Federal Court of Canada on behalf of a public transportation authority, against both the Canada Revenue Agency and the Québec Revenue Agency, against reassessments denying tax refunds for diesel fuel.

Sigdo Koppers

Acted as Canadian counsel to Sigdo Koppers, a Chilean industrial engineering conglomerate, in connection with its US$790-million acquisition of Magotteaux Group, a Belgian mining and cement services company.

Eurocopter Holding SAS

Acted for Eurocopter Holding SAS, a subsidiary of European Aeronautic Defence and Space Company EADS N.V., in connection with its acquisition of Vector Aerospace Corporation in a transaction valued at $635 million by way of a takeover bid.

Laurentides Investissements S.A.S.

Acted for Laurentides Investissements S.A.S., a subsidiary of ENGIE, in the sale of its interest in Noverco Inc., an investment company that controls natural gas distributor Énergir Inc., to the Caisse de dépôt et placement du Québec and Enbridge Inc.

Baosteel Resources International Co., Ltd.

Acted for Baosteel Resources International Co., Ltd., part of The Baosteel Group and one of the largest steel producers in China and worldwide, in connection with its investment in Noront Resources Ltd., by way of a private placement.

The Sentient Group

Acted for The Sentient Group with respect to its US$140-million divestiture of interest in Norsemont Mining Inc.

Arrow Electronics

Acted for Arrow Electronics in the acquisition of the RF, Wireless and Power Division of Richardson Electronics, Ltd., the leading global component distributor and provider of engineered solutions on the global radio frequency and wireless communications market.

Wellspring Capital Management LCC

Acted for Wellspring Capital Management LLC in connection to the acquisition by a wholly owned subsidiary of Packaging Solutions Holdings Inc. of the plastic flexible packaging business operated by Excel-Pac Inc., a Montréal-based manufacturer specializing in the dairy, food and confectionary markets.

Neucel Specialty Cellulose Ltd.

Acted for Neucel Specialty Cellulose Ltd., one of the world's top suppliers of specialty cellulose woodpulp, and for its majority shareholder, Neucel Specialty Cellulose Holdings LP, in connection with the sale of Neucel to Fulida Group Holding Ltd., an integrated textile manufacturer in China.

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.

Rossy and Assaly families

Acted for the founders of Dollarama Inc. in connection with a $282-million bought deal secondary offering of common shares and related over-allotment option in January, 2010 and in connection with a $287.5-million bought deal secondary offering of common shares and related over-allotment option in April, 2010.

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.

JP Morgan Partners, LLC

Acted for JP Morgan Partners, LLC and its affiliates in the sale of all the shares of Telesystem International Wireless Inc. for an aggregate amount of $830 million.

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.

Article

Investing In… 2024: Canada chapter, co-author

Jan. 01, 2024 - Chambers Global Practice Guides (Chambers and Partners)
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Article

Canada’s Digital Services Tax Move Still Sets Nothing in Stone, co-author

Dec. 14, 2023 - Bloomberg Tax (Bloomberg Industry Group, Inc.)
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Speaking Engagement

Canadian Tax Foundation, 75th Annual Tax Conference, “Limitation of Benefits (LOB)”; Montréal, QC

Nov. 27, 2023

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Canadian Federal Court of Appeal Gets Section 20(12) Right, author

July 17, 2023 - Tax Notes
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Article

The CRA Changes the Channel on Broadcast Rights, co-author

Feb. 01, 2023 - International Tax Highlights, Vol. 2, No. 1
Download the article.

Article

Investing In… 2023: Canada chapter, co-author

Jan. 19, 2023 - Chambers Global Practice Guides (Chambers and Partners)
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Bulletin

Highlights of Canada’s Latest Legislative Tax Proposals

Aug. 23, 2022 - The Department of Finance recently released a package of materials containing potential changes to the Canadian tax system (Tax Proposals). The materials, released on August 9, 2022, include draft amendments to the Income Tax Act (Tax Act) to implement certain measures from the 2022...

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Anti-Hybrid Rules Arrive (Finally) In Canada, co-author

June 20, 2022 - Tax Notes International, Vol. 106, No. 12 (Tax Analysts)
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Article

UK Upper Tribunal on Multilingual Tax Treaty Interpretation: The RBC v. HMRC Decision, co-author

June 01, 2022 - Wolters Kluwer International Tax (Wolters Kluwer)
Download the article.

Bulletin

Federal Budget 2022: Tax Highlights

Apr. 08, 2022 - On April 7, 2022 (Budget Day), the Honourable Chrystia Freeland, Deputy Prime Minister of Canada and Minister of Finance, delivered the Liberal Party’s federal budget (Budget 2022), the second budget since the start of the COVID-19 pandemic. As part of the Trudeau government’s plan to “grow our...

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Canadian Supreme Court Upholds Loblaw’s Offshore Bank Structure, co-author

Feb. 28, 2022 - Tax Notes International, Vol. 105, No. 9 (Tax Analysts)
Download this article.

Bulletin

Top Court Blesses Treaty-Shopping Arrangement: The Alta Energy Decision

Dec. 14, 2021 - The Supreme Court of Canada (SCC) recently rendered its eagerly awaited decision in Canada v Alta Energy Luxembourg S.A.R.L., 2021 SCC 49 (Alta Energy). Six of the nine justices held that the Canadian statutory general anti-avoidance rule (GAAR) did not apply to deny treaty...

Article

Canada at the Crossroads of International Tax Reform: Between Harmonization and Tax Competition, co-author

Oct. 26, 2021 - Bulletin for International Taxation, Vol. 75, No. 11/12 (IBFD)
Read the article (available for purchase).

Article

The Family Office of Tomorrow: A Canadian Perspective, co-author

Aug. 01, 2021 - Bulletin for International Taxation, Vol. 75, No. 8 (IBFD)
Read the article (available for purchase).

Article

Canada and BEPS: What Goes Around Comes Round, co-author

June 28, 2021 - Tax Notes International, Vol. 102, No. 13 (Tax Analysts)
Download this article.

Article

Was There a “Liquidation and Dissolution”? A (Corporate) Existential Question, co-author

June 01, 2021 - International Tax Newsletter, No. 118 (Wolters Kluwer)
Download this article.

Article

The Emergis Hybrid Financing Case: Déjà Vu?, co-author

May 03, 2021 - Tax Notes International, Vol. 102, No. 5 (Tax Analysts)
Download this article.

Bulletin

2021 Federal Budget: Tax Highlights

Apr. 20, 2021 - The Honourable Chrystia Freeland, Canada’s Deputy Prime Minister and Minister of Finance, delivered the Liberal Party’s first federal budget (Budget 2021) in over two years and the first since the start of the global COVID-19 pandemic. As part of a recovery plan for “jobs, growth and resilience,”...

Bulletin

The First Specified Transactions to Be Disclosed to Revenu Québec Announced

Mar. 24, 2021 - The Québec government announced in its March 21, 2019 budget a series of measures aimed at protecting the integrity and equity of Québec’s tax system. These measures include the mandatory disclosure of certain transactions1 ‒ those that are significantly similar to so-called determined...

Article

Montréal: North America’s Video Gaming Studio Metropolis

Feb. 17, 2021 - In this article originally published in Tax Notes International, Davies lawyers Michael Kandev and Olivia Khazam review Montréal’s generous provincial tax incentives for video game industry developers and investors, as well as some of the principal tax issues related to mergers and...

Article

Is a Green New (Tax) Deal Coming to Canada?

Feb. 02, 2021 - In this article originally published in Tax Notes International, Davies lawyers Gregg Benson, Michael Kandev and James Trougakos review Canadian tax incentives for green energy and juxtapose them with those offered by the United States. Download the article.

Bulletin

Canadian Tax Laws: A Review of 2020 and a Look Ahead to 2021

Jan. 28, 2021 - Review of Canadian Tax Developments in 2020 The year 2020 was anything but normal with the global COVID-19 pandemic creating both human and fiscal challenges in Canada and abroad. The federal government’s attention was fixed firmly on the pandemic for most of the year, and it was only in November...

Bulletin

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...

Speaking Engagement

APFF, 2020 Annual Conference, “International Tax Outlookˮ; Webinar

Oct. 08, 2020

Article

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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Speaking Engagement

Chartered Institute of Taxation, 10th Annual Joint International Tax Conference, “Emerging GAARs in International Tax”; Webinar

July 10, 2020

Article

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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Article

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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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)
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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.

Speaking Engagement

Chair, International Fiscal Association, US-Canada Joint Meeting, “M&A/Cross Border Structuring – United States to Canada Investment”; Boston, MA

Feb. 26, 2020

Bulletin

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...

Article

The OECD Multilateral Instrument: A Canadian Perspective on the Principal Purpose Test, co-author

Jan. 02, 2020 - Bulletin for International Taxation, Vol. 74, No. 1 (IBFD)
Read the article (available for purchase).

Article

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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Bulletin

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...

Article

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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Speaking Engagement

Moderator, IFA International Tax Conference 2019, “MLI Implementation and OECD Developments”; Montréal, QC

May 14, 2019

Bulletin

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,...

Article

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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Bulletin

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...

Bulletin

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

Article

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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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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Article

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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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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In the News

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...

Speaking Engagement

IFA International Tax Conference 2018, “Recent Developments of Interest”; Calgary, AB

May 16, 2018

Bulletin

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...

Speaking Engagement

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

Article

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.

Bulletin

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...

Bulletin

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....

Article

Impact of U.S. Tax Reform on Canadian Multinationals, co-author

Dec. 01, 2017 - International Tax Newsletter, No. 97 (Wolters Kluwer)
Download this article.

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)
Download this article.

Article

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.

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.

Bulletin

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...

Bulletin

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...

Article

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.

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.

Bulletin

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...

Article

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.

Bulletin

2016 Federal Budget: Tax Highlights

Mar. 22, 2016 - The new Liberal governments 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...

Bulletin

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...

Bulletin

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...

Chambers Global: The World’s Leading Lawyers for Business—Tax

Chambers Canada: Canada’s Leading Lawyers for Business—Tax

International Tax Review’s World Tax: The Comprehensive Guide to the World’s Leading Tax Firms—General Corporate Tax (Rising Star)

Lexpert Special Edition: Finance and M&A

The Lexpert/American Lawyer Guide to the Leading 500 Lawyers in Canada—Corporate Tax

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; Investment Funds and Asset Management: Investment Funds – Tax

The Best Lawyers in Canada—Mergers and Acquisitions Law; Tax Law

Who’s Who Legal: Canada—E-Discovery Practitioners

Bar Admissions

Québec, 2003
Ontario, 2002

Education

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

Professional Affiliations

Association de planification fiscale et financière
Canadian Tax Foundation
International Fiscal Association

Community Involvement

International Fiscal Association, Canada Council, president
Wolters and Kluwer International Tax Journal, contributing editor

Teaching Engagements

Michael has lectured on taxation at McGill University and Université de Montréal.