Nathan Boidman

Partner

Nathan Boidman

Nathan Boidman

Partner

Expertise
Bar Admissions
  • Québec, 1981

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.

Nathan Boidman

Partner

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.

CIT Group

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.

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

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...

Article

BEPS Cash Box Inconsistent with Canadian Tax Rules

Oct. 03, 2016 - Originally published in Canadian Tax Foundation, 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.

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, sheds light on how the simple notion underlying controlled foreign corporation attribution rules— that CFCs’ undistributed passive income should be...

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 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...

Article

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...

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 Outlook Key...

Article

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 of...

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

Expert Guides—Tax

Bar Admissions

Québec, 1981

Education

McGill University, BCL/LLB, 1980
McGill University, BComm, 1962

Professional Affiliations

Chartered Professional Accountants of Ontario
Ordre des comptables professionnels agréés du Québec, Fellow

Board Memberships

Canadian Tax Foundation, Board of Governors, former governor

Community Involvement

Canadian Bar Association and Chartered Professional Accountants of Canada, Joint Committee on Taxation, former member
Canadian Branch of the International Fiscal Association, Council member and former president
International Fiscal Association, former Executive Committee member

Teaching Engagements

Nat has lectured on taxation at the Université de Sherbrooke master’s program in taxation and at McGill and Concordia Universities.