Peter Glicklich

Partner

Peter A. Glicklich

Peter Glicklich

Partner

Expertise
Bar Admissions
  • Florida, 2017
    New York, 1982

Peter’s innovative and practical tax advice is informed by his sophisticated knowledge, wide-ranging experience and cross-border expertise.

Managing Partner in New York, Peter has 30 years of experience counselling corporations, institutional investors, banks, and public and private REITs on their international and corporate tax concerns. He advises on the tax implications of mergers and acquisitions, joint ventures, cross-border financings, restructurings, reorganizations, spinoffs and intercompany pricing. Peter also counsels wealthy families and advises on their transformative transactions and intergenerational transfers. Clients trust him to handle tax controversies or to arbitrate tax-related contract disputes arising from transactions.

Peter holds a leadership role in the International Fiscal Association and serves on the advisory boards of a number of prominent industry publications.

Peter Glicklich

Partner

Peter’s innovative and practical tax advice is informed by his sophisticated knowledge, wide-ranging experience and cross-border expertise.

Managing Partner in New York, Peter has 30 years of experience counselling corporations, institutional investors, banks, and public and private REITs on their international and corporate tax concerns. He advises on the tax implications of mergers and acquisitions, joint ventures, cross-border financings, restructurings, reorganizations, spinoffs and intercompany pricing. Peter also counsels wealthy families and advises on their transformative transactions and intergenerational transfers. Clients trust him to handle tax controversies or to arbitrate tax-related contract disputes arising from transactions.

Peter holds a leadership role in the International Fiscal Association and serves on the advisory boards of a number of prominent industry publications.

PSP Investments

Acted for PSP Investments in its strategic investment in SitusAMC, the leading provider of services and technology supporting the real estate finance industry.

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.

Business Development Bank of Canada

Acting for Business Development Bank of Canada in connection with the Government of Canada's Venture Capital Catalyst Initiative, which involves the formation of certain venture capital fund-of-funds. Northleaf Venture Catalyst Fund II, HarbourVest Canada Growth Fund II, Teralys Capital Innovation Fund and Kensington Venture Fund II, four of the five venture capital fund-of-funds established under the VCCI program, had their final closings in 2019.

Barrick Gold Corporation

Acted for Barrick Gold Corporation in its recommended US$18.3-billion share-for-share merger with Randgold Resources Limited. This complex and multijurisdictional transaction created an industry-leading gold company with the greatest concentration of tier one gold assets in the industry and a diversified asset portfolio positioned for growth.

Granite REIT

Acted as tax counsel to Granite REIT in its sale of a real estate portfolio in the United States and Canada for $400 million.

BlueCat Networks, Inc.

Acted for The Hyatt Family Trust in the sale of BlueCat Networks, Inc. to Madison Dearborn Partners LLC.

PSP Investments

Acted for PSP Investments in its strategic initiatives with Pattern Energy Group Inc., including (i) the acquisition of a 9.9% interest in Pattern Energy; (ii) the joint venture between PSP and Pattern Energy to co-invest in various renewable projects; (iii) the joint acquisition with Pattern Energy of a 51% and 49% interest, respectively, in the 179 MW Meikle wind project in British Columbia and the 143 MW Mont Sainte-Marguerite wind project in Québec; and (iv) the acquisition of 49% of the Class B interests held by Pattern in the Panhandle 2 wind project in Texas.

Northleaf Capital Partners

Acted for Northleaf Capital Partners in connection with the establishment of a US$1.4-billion Northleaf global private credit program and Northleaf's related acquisition, through a new Northleaf-managed investment fund, of a 16% equity stake in Antares Holdings from CPPIB Credit Investments Inc.

InstarAGF Asset Management Inc.

Acted for InstarAGF Asset Management Inc. in connection with the formation of InstarAGF Essential Infrastructure Fund with total equity capital commitments of $740 million.

Desjardins Securities Inc., CIBC World Markets Inc. and RBC Dominion Securities Inc.

Acted for a syndicate of underwriters led by Desjardins Securities Inc., CIBC World Markets Inc. and RBC Dominion Securities Inc. in connection with a US$69 million bought deal public offering of trust units issued by WPT Industrial REIT.

RioCan Real Estate Investment Trust

Acted for RioCan Real Estate Investment Trust on Canadian and US tax matters in connection with the US$1.9-billion sale of its portfolio of 49 shopping centres, located in the Northeastern U.S. and Texas, to Blackstone Real Estate Partners.

The Aristotle Corporation

Acted for The Aristotle Corporation in connection with the sale of that company to the private equity firm Wasserstein & Co. The Aristotle Corporation, headquartered in Fort Atkinson, WI, is a leading developer and value-added distributor of specialty products for the education, healthcare training, laboratory testing and agricultural end markets.

BMO Capital Markets and CIBC World Markets Inc.

Acted for a syndicate of underwriters co-led by BMO Capital Markets and CIBC World Markets Inc. in connection with a $143.9-million bought deal offering of subscription receipts of Milestone Apartments Real Estate Investment Trust. The proceeds from the offering were used to fund part of the purchase price for Milestone's $502-million acquisition of 15 properties from Landmark Apartment Trust, Inc.

Ironbridge Equity Partners

Acted for Ironbridge Equity Partners in connection with its investment in Alliance Corporation, a distributor and manufacturer of products and solutions for North American wireless, broadband, broadcast and wireline networks.

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.

Onex Corporation

Acted as Canadian counsel for Onex Partners in the $715-million financing in connection with the acquisition of York Risk Services Group, Inc.

Northleaf Mid-Market Infrastructure Partners

Acted for Northleaf Mid-Market Infrastructure Partners in connection with a series of subordinated loans made available to the consortium on the Colorado US 36 Express Lanes Project. The subordinated debt proceeds complement a US$60-million TIFIA loan from the U.S. Department of Transportation; a US$20-million tax-exempt private activity bond ("PABs") issue; US$2 million in net construction revenues; and a US$41-million capital contribution from the State of Colorado.

Brookfield Office Properties Inc.

Acted for Brookfield Office Properties Inc. and its independent committee in connection with the US$5-billion offer by its controlling shareholder, Brookfield Property Partners L.P., to acquire the minority interest in Brookfield Office Properties Inc.

Paladin Labs Inc.

Acted for Paladin Labs Inc. in connection with its acquisition by Endo Health Solutions Inc. in a stock and cash transaction valued at approximately $3 billion.

Meridiam Infrastructure, Bouygues Travaux Publics and Transfield Services Ltd.

Acted for the Miami Access Tunnel consortium, comprised of Meridiam Infrastructure, Bouygues Travaux Publics and Transfield Services Ltd. for the design, build, finance, operation and maintenance of the US$1.3 billion greenfield Port of Miami Tunnel project. Davies also acted as lead counsel for the consortium on the financing of the Project, with the senior debt financing of US$340 million being provided through a club of 10 international banks and the subordinated debt financing of US$341 million being provided as a 35-year fixed rate loan by the United States Department of Transportation under the federal TIFIA (Transportation Infrastructure Finance and Innovation Act of 1998) program. This project was awarded the 2009 Global PPP Deal of the Year by Project Finance magazine and the 2009 Americas PPP Deal of the Year by each of Project Finance International and Project Finance magazine.

H&R Real Estate Investment Trust

Acted for H&R Real Estate Investment Trust which effected a Plan of Arrangement transferring certain notes issued by H&R (U.S.) Holdings, Inc. (a wholly owned U.S. subsidiary of H&R) in the principal amount of US$125 million to H&R Finance Trust.

AbitibiBowater Inc.

Acted for AbitibiBowater Inc. (now known as Resolute Forest Products) in connection with the sale of its Snowflake, Arizona mill to Catalyst Paper Corporation in a transaction valued at US$161 million.

Barrick Gold Corporation

Acted for Barrick Gold Corporation in its pre-bid agreement with Goldcorp Inc. to dispose of certain assets acquired by Barrick in its takeover bid for Placer Dome Inc. and in the subsequent disposition of US$1.6 billion of assets to Goldcorp.

Bulletin

IRS Issues New Proposed Regulations Under the Section 1061 Carried Interest Rules

Sept. 29, 2020 - The U.S. Internal Revenue Service (IRS) published proposed regulations (the Proposed Regulations) on August 14, 2020, providing much-needed guidance on the implementation of the carried interest rules under Section 1061. 1 These rules will be of great interest to investment fund managers as well...

Bulletin

IRS Releases Final Regulations on Deductibility of Business Interest Expense

Aug. 05, 2020 - The IRS recently released long-awaited final regulations (Final Regulations) on the limitation on the deductibility of interest expenses under section 163(j), along with new proposed regulations (New Proposed Regulations) that address a variety of highly technical issues that are not covered by the...

Bulletin

IRS Finalizes High-Tax Exception to GILTI

July 22, 2020 - The U.S. Treasury Department and the IRS have released final regulations (2020 Final Regulations) allowing certain domestic shareholders of a “controlled foreign corporation” (CFC) to elect under a high-tax exception to opt out of the tax imposed on the CFC’s “global intangible low-taxed income”...

Bulletin

IRS Issues Final and Proposed Regulations on Hybrid Entities and Transactions

Apr. 15, 2020 - U.S. tax practitioners were the first to use hybrid instruments and entities in international tax planning. It is therefore neither surprising nor inappropriate that the United States was the first country (in 1997) to enact an anti-hybrid rule (in section 894(c) of the U.S. Internal Revenue...

Bulletin

U.S. Congress Provides COVID-19 Relief by Passing CARES Act

Mar. 30, 2020 - The emergence of COVID-19 has sent a shock wave through the world economy, resulting in significant disruption to the financial markets, the shuttering of entire industries and the lockdown of major cities across the globe. As a result, many national governments are applying every policy tool at...

Speaking Engagement

International Fiscal Association, US-Canada Joint Meeting, “US–Canada Income Tax Treaty”; Boston, MA

Feb. 26, 2020

American College of Tax Counsel—Fellow

New York Super Lawyers—Tax; International

American Lawyer’s New York Area’s Top Rated Lawyers

The Best Lawyers in America—Tax Law

Who’s Who Legal: Corporate Tax—Advisory; Who’s Who Legal: Thought Leaders—Corporate Tax

Bloomberg BNA—International Tax Contributor of the Year (2017)

Bar Admissions

Florida, 2017
New York, 1982

Education

Harvard Law School, JD (Cum Laude), 1981
University of Wisconsin–Madison, BA (with Highest Honors), 1977

Professional Affiliations

American Bar Association
American College of Tax Counsel, Fellow
New York State Bar Association

Board Memberships

Alliance for Cancer Gene Therapy, Chairman of the Executive Committee
Whitehead Institute for Biomedical Research, Board of Advisors

Community Involvement

American Bar Association, Tax Section, International Committee
Bloomberg BNA, U.S. International Tax Advisory Board, member and forum contributor
Bureau of National Affairs’ Tax Management International Journal, Advisory Board
Canadian Tax Journal, Advisory Board
Journal of International Taxation, Advisory Board
International Fiscal Association, USA Branch, Central IFA Executive Committee, vice-president and U.S. Representative
Memorial Union Building Association (University of Wisconsin–Madison), associate trustee
New York State Bar Association, Tax Section, International Committee

Peter’s innovative and practical tax advice is informed by his sophisticated knowledge, wide-ranging experience and cross-border expertise.

Managing Partner in New York, Peter has 30 years of experience counselling corporations, institutional investors, banks, and public and private REITs on their international and corporate tax concerns. He advises on the tax implications of mergers and acquisitions, joint ventures, cross-border financings, restructurings, reorganizations, spinoffs and intercompany pricing. Peter also counsels wealthy families and advises on their transformative transactions and intergenerational transfers. Clients trust him to handle tax controversies or to arbitrate tax-related contract disputes arising from transactions.

Peter holds a leadership role in the International Fiscal Association and serves on the advisory boards of a number of prominent industry publications.

PSP Investments

Acted for PSP Investments in its strategic investment in SitusAMC, the leading provider of services and technology supporting the real estate finance industry.

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.

Business Development Bank of Canada

Acting for Business Development Bank of Canada in connection with the Government of Canada's Venture Capital Catalyst Initiative, which involves the formation of certain venture capital fund-of-funds. Northleaf Venture Catalyst Fund II, HarbourVest Canada Growth Fund II, Teralys Capital Innovation Fund and Kensington Venture Fund II, four of the five venture capital fund-of-funds established under the VCCI program, had their final closings in 2019.

Barrick Gold Corporation

Acted for Barrick Gold Corporation in its recommended US$18.3-billion share-for-share merger with Randgold Resources Limited. This complex and multijurisdictional transaction created an industry-leading gold company with the greatest concentration of tier one gold assets in the industry and a diversified asset portfolio positioned for growth.

Granite REIT

Acted as tax counsel to Granite REIT in its sale of a real estate portfolio in the United States and Canada for $400 million.

BlueCat Networks, Inc.

Acted for The Hyatt Family Trust in the sale of BlueCat Networks, Inc. to Madison Dearborn Partners LLC.

PSP Investments

Acted for PSP Investments in its strategic initiatives with Pattern Energy Group Inc., including (i) the acquisition of a 9.9% interest in Pattern Energy; (ii) the joint venture between PSP and Pattern Energy to co-invest in various renewable projects; (iii) the joint acquisition with Pattern Energy of a 51% and 49% interest, respectively, in the 179 MW Meikle wind project in British Columbia and the 143 MW Mont Sainte-Marguerite wind project in Québec; and (iv) the acquisition of 49% of the Class B interests held by Pattern in the Panhandle 2 wind project in Texas.

Northleaf Capital Partners

Acted for Northleaf Capital Partners in connection with the establishment of a US$1.4-billion Northleaf global private credit program and Northleaf's related acquisition, through a new Northleaf-managed investment fund, of a 16% equity stake in Antares Holdings from CPPIB Credit Investments Inc.

InstarAGF Asset Management Inc.

Acted for InstarAGF Asset Management Inc. in connection with the formation of InstarAGF Essential Infrastructure Fund with total equity capital commitments of $740 million.

Desjardins Securities Inc., CIBC World Markets Inc. and RBC Dominion Securities Inc.

Acted for a syndicate of underwriters led by Desjardins Securities Inc., CIBC World Markets Inc. and RBC Dominion Securities Inc. in connection with a US$69 million bought deal public offering of trust units issued by WPT Industrial REIT.

RioCan Real Estate Investment Trust

Acted for RioCan Real Estate Investment Trust on Canadian and US tax matters in connection with the US$1.9-billion sale of its portfolio of 49 shopping centres, located in the Northeastern U.S. and Texas, to Blackstone Real Estate Partners.

The Aristotle Corporation

Acted for The Aristotle Corporation in connection with the sale of that company to the private equity firm Wasserstein & Co. The Aristotle Corporation, headquartered in Fort Atkinson, WI, is a leading developer and value-added distributor of specialty products for the education, healthcare training, laboratory testing and agricultural end markets.

BMO Capital Markets and CIBC World Markets Inc.

Acted for a syndicate of underwriters co-led by BMO Capital Markets and CIBC World Markets Inc. in connection with a $143.9-million bought deal offering of subscription receipts of Milestone Apartments Real Estate Investment Trust. The proceeds from the offering were used to fund part of the purchase price for Milestone's $502-million acquisition of 15 properties from Landmark Apartment Trust, Inc.

Ironbridge Equity Partners

Acted for Ironbridge Equity Partners in connection with its investment in Alliance Corporation, a distributor and manufacturer of products and solutions for North American wireless, broadband, broadcast and wireline networks.

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.

Onex Corporation

Acted as Canadian counsel for Onex Partners in the $715-million financing in connection with the acquisition of York Risk Services Group, Inc.

Northleaf Mid-Market Infrastructure Partners

Acted for Northleaf Mid-Market Infrastructure Partners in connection with a series of subordinated loans made available to the consortium on the Colorado US 36 Express Lanes Project. The subordinated debt proceeds complement a US$60-million TIFIA loan from the U.S. Department of Transportation; a US$20-million tax-exempt private activity bond ("PABs") issue; US$2 million in net construction revenues; and a US$41-million capital contribution from the State of Colorado.

Brookfield Office Properties Inc.

Acted for Brookfield Office Properties Inc. and its independent committee in connection with the US$5-billion offer by its controlling shareholder, Brookfield Property Partners L.P., to acquire the minority interest in Brookfield Office Properties Inc.

Paladin Labs Inc.

Acted for Paladin Labs Inc. in connection with its acquisition by Endo Health Solutions Inc. in a stock and cash transaction valued at approximately $3 billion.

Meridiam Infrastructure, Bouygues Travaux Publics and Transfield Services Ltd.

Acted for the Miami Access Tunnel consortium, comprised of Meridiam Infrastructure, Bouygues Travaux Publics and Transfield Services Ltd. for the design, build, finance, operation and maintenance of the US$1.3 billion greenfield Port of Miami Tunnel project. Davies also acted as lead counsel for the consortium on the financing of the Project, with the senior debt financing of US$340 million being provided through a club of 10 international banks and the subordinated debt financing of US$341 million being provided as a 35-year fixed rate loan by the United States Department of Transportation under the federal TIFIA (Transportation Infrastructure Finance and Innovation Act of 1998) program. This project was awarded the 2009 Global PPP Deal of the Year by Project Finance magazine and the 2009 Americas PPP Deal of the Year by each of Project Finance International and Project Finance magazine.

H&R Real Estate Investment Trust

Acted for H&R Real Estate Investment Trust which effected a Plan of Arrangement transferring certain notes issued by H&R (U.S.) Holdings, Inc. (a wholly owned U.S. subsidiary of H&R) in the principal amount of US$125 million to H&R Finance Trust.

AbitibiBowater Inc.

Acted for AbitibiBowater Inc. (now known as Resolute Forest Products) in connection with the sale of its Snowflake, Arizona mill to Catalyst Paper Corporation in a transaction valued at US$161 million.

Barrick Gold Corporation

Acted for Barrick Gold Corporation in its pre-bid agreement with Goldcorp Inc. to dispose of certain assets acquired by Barrick in its takeover bid for Placer Dome Inc. and in the subsequent disposition of US$1.6 billion of assets to Goldcorp.

Bulletin

IRS Issues New Proposed Regulations Under the Section 1061 Carried Interest Rules

Sept. 29, 2020 - The U.S. Internal Revenue Service (IRS) published proposed regulations (the Proposed Regulations) on August 14, 2020, providing much-needed guidance on the implementation of the carried interest rules under Section 1061. 1 These rules will be of great interest to investment fund managers as well...

Bulletin

IRS Releases Final Regulations on Deductibility of Business Interest Expense

Aug. 05, 2020 - The IRS recently released long-awaited final regulations (Final Regulations) on the limitation on the deductibility of interest expenses under section 163(j), along with new proposed regulations (New Proposed Regulations) that address a variety of highly technical issues that are not covered by the...

Bulletin

IRS Finalizes High-Tax Exception to GILTI

July 22, 2020 - The U.S. Treasury Department and the IRS have released final regulations (2020 Final Regulations) allowing certain domestic shareholders of a “controlled foreign corporation” (CFC) to elect under a high-tax exception to opt out of the tax imposed on the CFC’s “global intangible low-taxed income”...

Bulletin

IRS Issues Final and Proposed Regulations on Hybrid Entities and Transactions

Apr. 15, 2020 - U.S. tax practitioners were the first to use hybrid instruments and entities in international tax planning. It is therefore neither surprising nor inappropriate that the United States was the first country (in 1997) to enact an anti-hybrid rule (in section 894(c) of the U.S. Internal Revenue...

Bulletin

U.S. Congress Provides COVID-19 Relief by Passing CARES Act

Mar. 30, 2020 - The emergence of COVID-19 has sent a shock wave through the world economy, resulting in significant disruption to the financial markets, the shuttering of entire industries and the lockdown of major cities across the globe. As a result, many national governments are applying every policy tool at...

Speaking Engagement

International Fiscal Association, US-Canada Joint Meeting, “US–Canada Income Tax Treaty”; Boston, MA

Feb. 26, 2020

American College of Tax Counsel—Fellow

New York Super Lawyers—Tax; International

American Lawyer’s New York Area’s Top Rated Lawyers

The Best Lawyers in America—Tax Law

Who’s Who Legal: Corporate Tax—Advisory; Who’s Who Legal: Thought Leaders—Corporate Tax

Bloomberg BNA—International Tax Contributor of the Year (2017)

Bar Admissions

Florida, 2017
New York, 1982

Education

Harvard Law School, JD (Cum Laude), 1981
University of Wisconsin–Madison, BA (with Highest Honors), 1977

Professional Affiliations

American Bar Association
American College of Tax Counsel, Fellow
New York State Bar Association

Board Memberships

Alliance for Cancer Gene Therapy, Chairman of the Executive Committee
Whitehead Institute for Biomedical Research, Board of Advisors

Community Involvement

American Bar Association, Tax Section, International Committee
Bloomberg BNA, U.S. International Tax Advisory Board, member and forum contributor
Bureau of National Affairs’ Tax Management International Journal, Advisory Board
Canadian Tax Journal, Advisory Board
Journal of International Taxation, Advisory Board
International Fiscal Association, USA Branch, Central IFA Executive Committee, vice-president and U.S. Representative
Memorial Union Building Association (University of Wisconsin–Madison), associate trustee
New York State Bar Association, Tax Section, International Committee