Nathan Boidman

Counsel

Nathan Boidman

Nathan Boidman

Counsel

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

Counsel

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.

Nutrien Ltd.

Acting 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.

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.

Article

The U.S.’s Illusionary Turn to Territoriality

Feb. 12, 2018 - In this article from Tax Notes International, Davies partner Nathan Boidman contends that the sponsors of the Tax Cuts and Jobs Act not only failed to deliver on their promise of a territorial system for controlled foreign corporations, but also expanded the preexisting...

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 2017As we predicted...

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. Legislative...

Article

The Univar Appeal: A Pyrrhic Victory For Indirect Acquisitions in Canada

Oct. 30, 2017 - In this article published in Tax Notes International, Davies partner Nathan Boidman reviews the decision by the Federal Court of Appeal in Univar Holdco Canada ULC v. The Queen, particularly in the context of the 2016 Income Tax Act amendments concerning surplus stripping...

Article

Canada Persists With Plan to Punish Private Corporate Passive Reinvestment, co-author

Oct. 30, 2017 - Tax Notes International, Vol. 88, No. 5 (Tax Analysis)
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’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...

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.

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.

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.

Nutrien Ltd.

Acting 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.

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.

Article

The U.S.’s Illusionary Turn to Territoriality

Feb. 12, 2018 - In this article from Tax Notes International, Davies partner Nathan Boidman contends that the sponsors of the Tax Cuts and Jobs Act not only failed to deliver on their promise of a territorial system for controlled foreign corporations, but also expanded the preexisting...

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 2017As we predicted...

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. Legislative...

Article

The Univar Appeal: A Pyrrhic Victory For Indirect Acquisitions in Canada

Oct. 30, 2017 - In this article published in Tax Notes International, Davies partner Nathan Boidman reviews the decision by the Federal Court of Appeal in Univar Holdco Canada ULC v. The Queen, particularly in the context of the 2016 Income Tax Act amendments concerning surplus stripping...

Article

Canada Persists With Plan to Punish Private Corporate Passive Reinvestment, co-author

Oct. 30, 2017 - Tax Notes International, Vol. 88, No. 5 (Tax Analysis)
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’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...

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.

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.