A “guru of international cross-border structuring,” Nat has 40 years of experience providing clients with “unrivalled international tax expertise.” (Chambers Global 2014, Legal 500 Canada 2016)
Nat advises clients on international tax, with a focus on cross-border mergers and acquisitions, financings, joint ventures, partnerships and business trusts. Canadian and international companies of varying sizes – across all industries – value Nat for his responsiveness and his keen awareness of the legal and business issues that matter to them. He also counsels clients on transfer pricing and other cross-border tax disputes with the Canada Revenue Agency. Individual clients consult him on international tax issues.
A prolific author and speaker, Nat has held senior leadership positions in leading industry associations, including the International Fiscal Association and the Canadian Tax Foundation. Before his law career, Nat was a partner in an accounting firm, where he specialized in tax.
Kimco Realty Corporation
Acted for Kimco Realty Corporation, a leading U.S.-based publicly-traded REIT, in connection with a partnership with Sandalwood Management Canada Co. to acquire more than 1 million square feet of retail property comprised of six shopping centers in the Province of Québec.
Circuit City Stores, Inc.
Acted for Circuit City Stores, Inc. on its acquisition of InterTAN, Inc., the operator of Radio Shack stores in Canada, in a transaction valued at approximately US$286 million to create The Source.
Euro-Pro Corporation and Omega Sewmac Inc.
Acted for Euro-Pro Corporation and Omega Sewmac Inc. in regard to the sale of their businesses to Euro-Pro Operating LLC and the related financing.
Diamond Fields Resources
Acted for Diamond Fields, as well as one of its two major shareholders, in its $4-billion sale to Inco.
Acted for CIT Group in its $3-billion takeover bid for Newcourt Credit Group Inc.
Potash Corporation of Saskatchewan Inc.
Acted for Potash Corporation of Saskatchewan Inc., providing tax advice in connection with a US$500-million bond offering.
International Petroleum Investment Company
Acting as Canadian tax counsel for International Petroleum Investment Company, an Abu Dhabi-based sovereign wealth fund, in connection with its planned merger with Abu Dhabi-based Mubadala Development Company.
Potash Corporation of Saskatchewan Inc.
Acting as Canadian tax counsel for Potash Corporation of Saskatchewan Inc. in connection with its announced US$36-billion merger of equals with Agrium Inc. to create a world-class integrated global supplier of crop inputs.
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.
The Sentient Group
Acted for The Sentient Group with respect to its US$140-million divestiture of interest in Norsemont Mining Inc.
Canada’s Enhanced Transitional Rules for U.S. LLPs and LLLPs
June 15, 2017 - In this article from Tax Notes International, Davies partner Nathan Boidman provides updates about the Canada Revenue Agency’s May 26, 2016, non-binding administrative decision to treat certain U.S. limited liability partnerships (LLPs) and limited liability limited partnerships (LLLPs) as...
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, the authors examine the extent to which Canada’s new treaties with Taiwan and Israel reflect its involvement and concern. Download this article.
Judicial and Legislative Developments Threaten Indirect Canadian Acquisitions
Oct. 10, 2016 - Originally published in Tax Notes International, this article examines new obstacles to the recovery by foreign parties of funds that were invested to indirectly acquire, through foreign companies, Canadian targets, raised by the recent decision in Univar and related proposed amendments to certain...
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.
Foreign Banks and Canada’s CFC System
Aug. 15, 2016 - Originally published in Tax Notes International, this article examines the Tax Court of Canada’s CIT judgment, as well as two pending companion cases, and sheds light on how the simple notion underlying controlled foreign corporation attribution rules— that CFCs’ undistributed passive income should...
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.
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 Transfer Pricing Decision in Marzen: Points of Interest
Feb. 15, 2016 - In this article from Tax Notes International, Davies partner Nathan Boidman reviews Marzen Artistic Aluminum, a Canadian transfer pricing case involving sales of Canadian products into U.S. markets. Nathan focuses on novel issues raised by the parties’ use of a Barbados subsidiary in the operating...
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 Key...
Chambers Global: The World’s Leading Lawyers for Business—Tax
Chambers Canada: Canada’s Leading Lawyers for Business—Tax
International Fiscal Association, Canadian branch—Lifetime Honorary Membership
The Lexpert/American Lawyer Guide to the Leading 500 Lawyers in Canada—Corporate Tax
Report on Business/Lexpert Special Edition Canada’s Leading Corporate Lawyers
Lexpert Guide to the Leading US/Canada Cross-Border Corporate Lawyers in Canada—Corporate Tax
The Canadian Legal Lexpert Directory—Corporate Tax (Most Frequently Recommended)
Who’s Who Legal: Canada—Corporate Tax; Who’s Who Legal: Corporate Tax—Advisory