“Obviously he has outstanding technical skills, but what sets him apart from other practitioners is that he is thoughtful in his advice, practical, business-oriented and very responsive.”
World Tax
Ian draws on more than 25 years of experience to advise clients on a wide range of domestic and cross-border mergers, acquisitions, investments and financings. Known for his expertise across diverse industries, Ian is relied on by clients for ongoing strategic and general tax advice.
He regularly advises Canada-based multinationals on their international tax matters and assists corporations with their reorganization and restructuring activities. Private equity fund clients turn to Ian for his extensive experience in advising on fund formation and fund investments.
Ian is considered a trusted adviser who brings “a new perspective” to our clients’ issues. (Chambers Canada 2016)
Ian is co-chair, legal, of the HSC Industry Leaders fundraising campaign.
Premium Brands Holdings Corporation
Acting for Premium Brands Holdings Corporation in its groundbreaking partnership with a coalition of Mi'kmaq First Nations to jointly acquire Clearwater Seafoods Incorporated, Atlantic Canada's largest wild seafood company, for approximately $1 billion.
Northleaf Capital Partners
Acting for Northleaf Capital Partners in its strategic sale of a non-controlling interest to Mackenzie Financial Corporation, a subsidiary of IGM Financial Inc., and Great-West Lifeco Inc.
InstarAGF Asset Management Inc.
Acted for InstarAGF Asset Management Inc. in the formation of US$1.2-billion InstarAGF Essential Infrastructure Fund II, an infrastructure fund focused on investments in North America, with limited partners from Canada, U.S., Europe and Asia.
Healthcare of Ontario Pension Plan
Acted for Healthcare of Ontario Pension Plan on its minority equity investment in Herschel Supply Co., a design-driven global lifestyle brand.
Canadian Business Growth Fund
Acted for Canada's leading banks and insurance companies to form the Canadian Business Growth Fund, an independent evergreen fund with a national mandate to provide long-term patient, minority capital to entrepreneurs pursuing growth and expansion strategies.
Birch Hill Equity Partners
Acted for Birch Hill Equity Partners in connection with its acquisition of a majority stake in Cozzini Bros., an Illinois-based knife sharpening rental and exchange company.
500 Startups
Acted for 500 Startups in the formation of its first Canadian venture capital seed fund.
Cadillac Fairview Corporation
Acted for Cadillac Fairview Corporation in the sale of a 50% non-managing interest in its Vancouver portfolio, including CF Pacific Centre and 12 office towers, to Ontario Pension Board and the Workplace Safety and Insurance Board.
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.
Oxford Park Group
Acted for Oxford Park Group in the formation of PointNorth Capital LP, a fund that continued Oxford Park's strategy of making special situation investments.
Cadillac Fairview Corporation Limited
Acted for Cadillac Fairview Corporation Limited in connection with the sale of a 30% non-managing interest in the Toronto-Dominion Centre and a concurrent sale of 30% interest in an office development site at 16 York Street to the Ontario Pension Board.
Bentall Kennedy (Canada) Limited Partner
Acted for the Bentall Kennedy Group, a premier real estate investment management firm operating in Canada and the United States, in its acquisition by Sun Life Financial Inc. for a purchase price of $560 million.
Alfa S.A.B. de C.V.
Acted for Alfa S.A.B. de C.V. in connection with its proposed acquisition, with Harbour Energy Ltd., of all of the outstanding common shares of Pacific Rubiales Energy Corp. for an all-cash purchase price of approximately $1.7 billion, plus the assumption of approximately $5 billion in debt. The acquisition was structured as a plan of arrangement under the Business Corporations Act (British Columbia).
RBC Capital Markets Inc.
Acted for a syndicate of underwriters led by RBC Capital Markets in connection with Chesswood Group Limited's $32-million public offering and $6-million private placement of subscription receipts. The proceeds from the offerings were used to partially finance the purchase price for Chesswood's $64-million acquisition of Blue Chip Leasing Corporation and EcoHome Financial Inc.
Major shareholder of Porter Aviations Holdings Inc.
Acted for a major shareholder of Porter Aviation Holdings Inc. in the sale of the passenger terminal at Billy Bishop Toronto City Airport to Nieuport Aviation Infrastructure Partners, a consortium of Canadian and international infrastructure investors, including AGF Management Ltd.'s InstarAGF Asset Management Inc.
Temasek Holdings (Private) Limited
Acted for Temasek Holdings (Private) Limited in connection with its investment, together with CEF Holdings Limited, in Magris Resources Inc. to fund Magris' initial acquisition of Iamgold Corp's Niobec mine for approximately US$530 million.
Fronteer Gold Inc.
Acted for Fronteer Gold Inc. in its $2.3-billion acquisition by Newmont Mining Corporation (now known as Newmont Goldcorp Corporation). The transaction was structured as a plan of arrangement providing for cash consideration and the spin off of shares of Pilot Gold Inc., a new TSX-listed company holding exploration assets, to the former shareholders of Fronteer Gold.
TPG Partners V LP
Acted for TPG Partners V LP in connection with its acquisition of Axcan Pharma Inc. in an all-cash transaction valued at US$1.3 billion.
Reuters Group PLC
Acted as Canadian counsel for Reuters Group PLC in its dual-listed company merger with The Thomson Corporation to create Thomson-Reuters in a transaction valued at US$17.6 billion, creating the first Canadian dual-listed company structure.
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 2019 Tax...
Bulletin
Draft Legislation on the Taxation of Stock Options
June 19, 2019 - The federal government has released much anticipated draft legislation proposing changes to the rules relating to the taxation of stock options. The legislative proposals are expected to come into force on January 1, 2020, and to apply to option agreements entered into after 2019. The release, on...
Bulletin
Canadian and U.S. Tax Laws: A Review of 2018 and a Look Ahead to 2019
Jan. 31, 2019 - In our annual Tax Review and Outlook report, we look back at significant developments in the Canadian and U.S. tax landscapes in 2018 and offer our predictions on what to expect in 2019. Key Canadian Developments in 2018 Budget 2018 scaled back controversial initiative on taxation of passive...
Bulletin
Canadian Tax Laws: A Review of 2018 and a Look Ahead to 2019
Jan. 31, 2019 - 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. Legislative Developments in 2018 Budget 2018 A. ...
Bulletin
Tax Court Finds That Broker Fees on a Private Company Sale Were GST/HST-Taxable
May 10, 2018 - The Tax Court of Canada recently released its decision in Barr v. The Queen, 2018 TCC 86, which considered whether share-sale commissions were exempt from HST. The taxpayer was the sole shareholder of a Canadian company. He had retained two brokers for the sale of his company or its...
Bulletin
2018 Federal Budget: Tax Highlights
Feb. 27, 2018 - As anticipated, today’s federal budget (Budget 2018) focuses on a few targeted areas, including the taxation of passive investments made by private corporations, and does not contain any measures in response to the enactment of tax reform in the United States or relating to the OECD BEPS...
In the News
Ian Crosbie Reacts to Federal Court of Appeal Decision in Lawyer’s Daily
Feb. 23, 2018 - In a recent article (available to subscribers) published in The Lawyer’s Daily, Davies partner Ian Crosbie commented on the decision of the Federal Court of Appeal (FCA) in Canada v. Oxford Properties Group Inc. The case centred on a number of transactions undertaken by Oxford...
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 2017 As we...
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...
Bulletin
Department of Finance Releases Revised Income Splitting Rules
Dec. 13, 2017 - Earlier this year, the Department of Finance released a set of far-reaching proposals affecting the taxation of private businesses and their shareholders. Only Rip Van Winkle missed the firestorm reaction to these proposals from a broad range of affected parties. Ultimately, the Government...
Bulletin
2017 Federal Budget: Tax Highlights
Mar. 22, 2017 - The Liberal government’s second budget (Budget 2017) comes during a period of exceptional global political and economic uncertainty. Of particular importance from a Canadian economic and tax policy perspective is the uncertainty about how the Trump administration’s agenda will unfold in the coming...
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...
Bulletin
The Federal Court of Appeal Permits Use of Mark-To-Market Tax Accounting
June 24, 2016 - The Federal Court of Appeal has held in the Kruger Inc. v. Canada decision published yesterday, that Kruger Inc. was entitled to use the mark-to-market method in computing its income for federal income tax purposes. As a result, for income tax purposes it was entitled to recognize an...
Bulletin
To Go or Not to Go? The 30% Rule for Canadian Pension Funds
June 06, 2016 - Canadian pension funds and their subsidiaries are subject to a rule that prohibits them from investing in shares of a corporation having more than 30% of the votes for the election of directors, except in the case of qualifying real estate, resource and investment subsidiaries (the so-called 30%...
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...
Bulletin
Recent Developments in Ontario Real Estate
Feb. 26, 2016 - Ontario Court of Appeal Rules on Assignment of Lease by Tenant The Ontario Court of Appeal recently released its decision in Hudson’s Bay Company v. OMERS Realty Corporation, a case that involved the assignment and sublease of the tenant’s interest in anchor tenant leases at Yorkdale,...
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 ...
Bulletin
Ontario Proposes Abolishing the Pension Fund “30% Rule”
Dec. 02, 2015 - Canadian pension funds and their subsidiaries are subject to rules that prohibit them from investing in shares of a corporation having more than 30% of the votes for the election of directors, except in the case of qualifying real estate, resource and investment subsidiaries (the so-called 30%...
Bulletin
Finance Minister Provides Guidance on Stock Option Grandfathering
Nov. 20, 2015 - The newly elected Liberal government indicated in its election platform that it intends to increase taxes on employee stock option benefits by limiting Canadian resident employees from claiming the stock option deduction (i.e., the capital gains equivalent taxation) in respect of option benefits in...
Bulletin
Will Tax Treatment for Canadian Stock Options Change?
Oct. 29, 2015 - The newly elected Liberal government indicated in its election platform that it intends to increase taxes on employee stock option benefits by limiting Canadian resident employees from claiming the stock option deduction (i.e., the capital gains equivalent taxation) in respect of option benefits in...
Bulletin
IRS Announces Expanded “No-Rule” Area for Spinoffs
Sept. 16, 2015 - On January 27, 2015, Yahoo Inc. announced its intention to seek an IRS private ruling that would confirm its view that the inclusion of a relatively small active business along with its stake in Alibaba Group Holding Ltd. would meet the “ active business requirement ” for a tax-deferred spinoff...
Bulletin
2015 Federal Budget: Tax Highlights
Apr. 21, 2015 - As has been widely predicted, today’s federal budget (Budget 2015) delivered a handful of tax “ goodies ” in the lead-up to the coming election. It also includes a number of important proposed changes to the corporate tax rules. They are noteworthy, although not as extensive as the corporate tax...
Bulletin
Canadian and U.S. Tax Law: A Review of 2014 and a Look Forward to 2015
Jan. 13, 2015 - 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 forward to possible Canadian and U.S. tax developments in the coming year. I. CANADIAN TAX REVIEW AND OUTLOOK A. ...