Nathan Boidman

Senior Counsel

Nathan Boidman

Nathan Boidman

Senior Counsel

Expertise
Bar Admissions
  • Québec, 1981

Nat has more than 45 years of experience providing clients with outstanding international tax expertise.

He 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

Senior Counsel

Nat has more than 45 years of experience providing clients with outstanding international tax expertise.

He 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.

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.

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.

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.

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

Acted as Canadian tax counsel for International Petroleum Investment Company, an Abu Dhabi-based sovereign wealth fund, on its merger with Mubadala Development Company, creating the 14th largest state-owned investment fund in the world with $125-billion in combined total assets and businesses in over 30 countries.

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.

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 centres 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.

CIT Group

Acted for CIT Group in its $3-billion takeover bid for Newcourt Credit Group Inc.

Diamond Fields Resources

Acted for Diamond Fields, as well as one of its two major shareholders, in its $4-billion sale to Inco.

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.

Article

How Will Revised Sourcing Rules Affect Sales Of U.S.-Made Goods Abroad?

Feb. 10, 2020 - Tax Notes International, Vol. 97, No. 6 (Tax Analysts)
Download this article.

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 2019Tax...

Article

GILTI and Canadian CFCs Under Recent Regulations

Jan. 10, 2020 - Tax Management International Journal, Vol. 49, No. 1 (Bloomberg TAX)
Download this article.

Article

Glencore: Australian Court Relies on Cameco

Dec. 01, 2019 - International Tax Journal, Vol. 109 (Wolters Kluwer)
Download this article.

Article

Is Corporate Tax Abolition Unrealistic

Nov. 04, 2019 - Tax Notes International, Vol. 96, No. 5 (Tax Analysts)
Download this article.

Article

Letter to the Editor: Wealth Tax Proposals — Taxation or Confiscation?

Oct. 21, 2019 - Tax Notes International, Vol. 96, No. 3 (Tax Analysts)
Download this article.

Article

Canada Enacts Multilateral Instrument: What Happens Next?, co-author

July 22, 2019 - Tax Notes International, Vol. 95, No. 4 (Tax Analysts)
Download this article.

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 be...

Article

Proposed U.S. Regs Narrow GILTI Exposure on Canadian CFC Operations

June 03, 2019 - Tax Notes International, Vol. 94, No. 10 (Tax Analysts)
Download this article.

Chambers Global: The World’s Leading Lawyers for Business—Tax (Senior Statesperson)

Chambers Canada: Canada’s Leading Lawyers for Business—Tax (Senior Statesperson)

International Fiscal Association, Canadian branch—Lifetime Honorary Membership

International Tax Review’s World Tax: The Comprehensive Guide to the World’s Leading Tax Firms—Tax Controversy

Lexpert Guide to the Leading US/Canada Cross-Border Corporate Lawyers in Canada—Corporate Tax

The Canadian Legal Lexpert Directory—Corporate Tax

The Best Lawyers in Canada—Tax Law (Lawyer of the Year 2020, Montréal)

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.

Nat has more than 45 years of experience providing clients with outstanding international tax expertise.

He 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.

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.

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.

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.

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

Acted as Canadian tax counsel for International Petroleum Investment Company, an Abu Dhabi-based sovereign wealth fund, on its merger with Mubadala Development Company, creating the 14th largest state-owned investment fund in the world with $125-billion in combined total assets and businesses in over 30 countries.

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.

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 centres 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.

CIT Group

Acted for CIT Group in its $3-billion takeover bid for Newcourt Credit Group Inc.

Diamond Fields Resources

Acted for Diamond Fields, as well as one of its two major shareholders, in its $4-billion sale to Inco.

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.

Article

How Will Revised Sourcing Rules Affect Sales Of U.S.-Made Goods Abroad?

Feb. 10, 2020 - Tax Notes International, Vol. 97, No. 6 (Tax Analysts)
Download this article.

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 2019Tax...

Article

GILTI and Canadian CFCs Under Recent Regulations

Jan. 10, 2020 - Tax Management International Journal, Vol. 49, No. 1 (Bloomberg TAX)
Download this article.

Article

Glencore: Australian Court Relies on Cameco

Dec. 01, 2019 - International Tax Journal, Vol. 109 (Wolters Kluwer)
Download this article.

Article

Is Corporate Tax Abolition Unrealistic

Nov. 04, 2019 - Tax Notes International, Vol. 96, No. 5 (Tax Analysts)
Download this article.

Article

Letter to the Editor: Wealth Tax Proposals — Taxation or Confiscation?

Oct. 21, 2019 - Tax Notes International, Vol. 96, No. 3 (Tax Analysts)
Download this article.

Article

Canada Enacts Multilateral Instrument: What Happens Next?, co-author

July 22, 2019 - Tax Notes International, Vol. 95, No. 4 (Tax Analysts)
Download this article.

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 be...

Article

Proposed U.S. Regs Narrow GILTI Exposure on Canadian CFC Operations

June 03, 2019 - Tax Notes International, Vol. 94, No. 10 (Tax Analysts)
Download this article.

Chambers Global: The World’s Leading Lawyers for Business—Tax (Senior Statesperson)

Chambers Canada: Canada’s Leading Lawyers for Business—Tax (Senior Statesperson)

International Fiscal Association, Canadian branch—Lifetime Honorary Membership

International Tax Review’s World Tax: The Comprehensive Guide to the World’s Leading Tax Firms—Tax Controversy

Lexpert Guide to the Leading US/Canada Cross-Border Corporate Lawyers in Canada—Corporate Tax

The Canadian Legal Lexpert Directory—Corporate Tax

The Best Lawyers in Canada—Tax Law (Lawyer of the Year 2020, Montréal)

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.