Glencore Canada Corporation, 2024
Acted for Glencore Canada Corporation in its dispute before the Tax Court of Canada and Federal Court of Appeal with respect to the tax treatment of break fees.
Tax
Siemens Energy, 2023
Acting as Canadian tax counsel to Siemens Energy in the sale of Trench business in Canada to Triton, a leading European mid-market private equity investor.
Sprott Resource Streaming and Royalty Corp., 2023
Acted as tax counsel for Sprott Resource Streaming and Royalty Corp., as lead arranger for its resource lending investment funds, in its holistic financing solution provided to Bunker Hill in respect of its zinc, lead and silver project located in Idaho, U.S. The financing package included a debt facility, convertible debentures, a royalty convertible debenture and a streaming arrangement in respect of the project.
Sprott Resource Streaming and Royalty Corp., 2023
Acted as tax counsel for Sprott Resource Streaming and Royalty Corp., as lead arranger for its resource lending investment funds, in its acquisition of a secured note convertible into a gross revenue royalty of 4.75% of the gold and silver produced by Paramount Gold Nevada Corp.’s Grassy Mountain gold mine in eastern Oregon.
Foodtastic Inc., 2023
Acted as tax counsel to Foodtastic Inc., a leading franchisor of restaurant brands in Canada, in its C$74.4-million acquisition of Freshii Inc.
Sprott Resource Streaming and Royalty Corp., 2023
Acted as tax counsel for Sprott Resource Streaming and Royalty Corp., as lead arranger for its resource lending investment funds, in its acquisition of a secured note convertible into a streaming arrangement in respect of the gold produced by Theta Gold Mines Ltd.’s TGME Gold Project in South Africa.
Apotex Pharmaceutical Holdings Inc., 2023
Acted as lead transaction and tax counsel to Apotex Pharmaceutical Holdings Inc., a global pharmaceutical company that produces high-quality affordable medicine, in its sale to SK Capital Partners.
Apotex International Inc., 2023
Acted as lead tax counsel and Canadian transaction counsel to Apotex International Inc., a global pharmaceutical company that produces high-quality affordable medicine, in the sale of a 50% interest in Arrotex Pharmaceuticals (Australia) to DBG Health.
CAE Inc., 2023
Acted for CAE Inc. before the Federal Court of Appeal and their leave application to the Supreme Court of Canada in their dispute against the Canada Revenue Agency with respect to the characterization of an unconditionally refundable loan from the Government of Canada, namely for Scientific Research and Experimental Development (SRED) purposes, as “governmental assistance”.
Sprott Resource Lending Corp., 2023
Acted as tax counsel to Sprott Resource Lending Corp., as lead arranger for its resource lending investment funds, in the financing of Metals Acquisition Corp’s US$1.1-billion acquisition of Glencore’s CSA copper mine in New South Wales, Australia.
Sprott Resource Lending Corp., 2023
Acted as tax counsel to Sprott Resource Lending Corp., as lead arranger for its resource lending investment funds, in the US$150-million financing of Foran Mining Corporation’s McIvenna Bay project in east-central Saskatchewan.
Sprott Resource Streaming and Royalty Corp., 2023
Acted as tax counsel for Sprott Resource Streaming and Royalty Corp., as lead arranger for its resource lending investment funds, in its US$110-million streaming transaction with Ascot Resources Ltd. regarding the Premier Gold Project located on Nisga’a Nation Treaty Lands in the prolific Golden Triangle of northwestern British Columbia.
Sprott Resource Streaming and Royalty Corp., 2023
Acted as tax counsel for Sprott Resource Streaming and Royalty Corp., as lead arranger for its resource lending investment funds, in its streaming transaction with Cerrado Gold Inc. regarding gold and silver produced by its Monte do Carmo project in Brazil.
Real Estate Joint Venture, 2023
Acting for a real estate joint venture before the Court of Québec in a tax dispute against Revenu Québec with respect to the characterization of tenant inducement payments.
OMERS Capital Markets, 2022
Acted for OMERS Capital Markets in its US$500-million acquisition of 30% of Ultragenyx Pharmaceutical Inc.'s royalty interest from Kyowa Kirin Co., Ltd. on the future sales of Crysvitar (burosumab) in the United States and Canada.
AutoCanada Inc., 2022
Acted for AutoCanada Inc. in its C$100-million substantial issuer bid by “modified Dutch auction” pursuant to which AutoCanada repurchased C$32.5 million of its common shares.
Barrick Gold Corporation, 2022
Acted for Barrick Gold Corporation in its C$30-million sale to Montage Gold Corp. of the Mankono-Sissédougou joint venture project with Endeavour Mining plc.
Ironbridge Equity Partners, 2022
Acted for Ironbridge Equity Partners in the sale of its portfolio company, Thermogenics Inc., to Audax Private Equity.
Ferguson plc, 2022
Acted as Canadian counsel to Ferguson plc, the world's largest distributor of heating and plumbing products, in its acquisition of Canadian Safe-Step Tubs Inc. and its subsidiary, Safe-Step Tubs Northwest, Inc.
Sprott Resource Lending Corp., 2022
Acted as tax counsel for Sprott Resource Lending Corp., as lead arranger for its resource lending investment funds, in the US$225-million financing of Marathon Gold Corporation’s Valentine Gold project located in the central region of Newfoundland and Labrador.
Haven Interactive Studios Inc., 2022
Acted as Canadian counsel for Haven Entertainment Studios Inc., Montréal-based video game studio, in its sale to a wholly owned subsidiary of Sony Interactive Entertainment LLC.
Sprott Inc., 2022
Acted as tax counsel for Sprott Resource Streaming and Royalty Corp., as lead arranger for its resource lending investment funds and other institutional co-investors, in the acquisition from KSM Mining ULC of (i) a US$225M secured note to be exchanged on maturity for a gross silver royalty on the KSM project located in northern British Columbia; and (ii) a US$150M secured note to be exchanged on maturity for a 1.2% net smelters royalty on all metals produced by the same project.
Sprott Resource Streaming and Royalty Corp., 2022
Acted as tax counsel for Sprott Resource Streaming and Royalty Corp., as lead arranger for its resource lending investment funds, in the acquisition from Ascendant Resources of a secured note to be exchanged on maturity a streaming arrangement in respect of 1.75% of all metals produced from the Lagoa Salgada VMS projected in Lisbon, Portugal.
Individuals, 2022
Acted for individuals before the Tax Court of Canada in their dispute against the Canada Revenue Agency with respect to the purported application of the General Anti-Avoidance Rule following the intergenerational transfer of their business.
Sprott Resource Streaming and Royalty Corp., 2022
Acted as tax counsel for Sprott Resource Streaming and Royalty Corp., as lead arranger for its resource lending investment funds, in its US$37.5-million streaming transaction with Trigon Metals Inc. regarding silver and copper produced from its Kombat Mine located in Namibia.
Sprott Resource Streaming and Royalty Corp., 2022
Acted as tax counsel for Sprott Resource Streaming and Royalty Corp., as lead arranger for its resource lending investment funds, in (i) the financing of Northern Graphite Corporation’s acquisition of the Lac des Iles graphite mine in Québec and the Okanjande graphite deposit/Okorusu processing plant in Namibia; (ii) a 9% royalty on graphite concentrate sales revenue from the Lac des Iles graphite mine; (iii) a streaming arrangement on 11.25% of the graphite produced in Namibia.
Sprott Resource Streaming and Royalty Corp., 2022
Acted as tax counsel for Sprott Resource Streaming and Royalty Corp., as lead arranger for its resource lending investment funds, in its streaming transaction with South Star Battery Metals regarding Graphite produced by its Santa Cruz Project in Brazil.
Sprott Resource Streaming and Royalty Corp., 2022
Acted as tax counsel for Sprott Resource Streaming and Royalty Corp., as lead arranger for its resource lending investment funds, in its streaming transaction with Golden Sun Resources, the largest mining and exploration group in Costa Rica regarding the Bellavista Mine in Costa Rica.
Connor Clark & Lunn Infrastructure, 2022
Acted as tax counsel to Connor Clark & Lunn Infrastructure in its acquisition of Landmark Student Transportation, a leading student transportation businesses in North America.
Ghermezian Family, 2022
Acting for six members of the Ghermezian family before the Federal Court of Appeal and the Federal Court contesting compliance order applications by the Minister of National Revenue.
National Money Mart, 2022
Acting for National Money Mart in a dispute before the Tax Court of Canada involving whether services rendered with respect to pre-paid credit cards constitute "financial services" under the Excise Tax Act.
Granite Real Estate Investment Trust, 2021
Acted as tax counsel to Granite REIT in the establishment of a $250-million at-the- market equity distribution program.
Granite Real Estate Investment Trust, 2021
Acted as tax counsel to Granite REIT in its $500-million green bond offering of 2.194% Series 6 senior unsecured debentures.
Granite Real Estate Investment Trust, 2021
Acted as tax counsel to Granite REIT in its $316-million bought deal equity offering of stapled units.
Grimco Canada, Inc, 2021
Acted for Grimco Canada, Inc., a national wholesale sign supply manufacturer and distributor, in its acquisition of Cobalt Graphics Distribution, a division of Cansel Survey Equipment, Inc.
Sprott Resource Lending Corp., 2021
Acted as tax counsel to Sprott Resource Lending Corp., as lead arranger for its resource lending investment funds, in the acquisition of a convertible senior financing in support of Treasury Metals Inc.'s Goliath Gold Complex Projects in Ontario; and (ii) a 1.5% non-core net smelter return royalty on the Goldlund gold property in Ontario.
Ceská zbrojovka Defense SE, 2021
Acted as Canadian counsel for Ceská zbrojovka Group SE (CZG), a firearms manufacturer based in the Czech Republic, in its acquisition of 100% of the outstanding equity interest in Colt Holding Company LLC, the parent company of the storied U.S. firearms manufacturer Colt's Manufacturing Company LLC, as well as its Canadian subsidiary, Colt Canada Corporation.
Highshare Inc., 2021
Acting for various taxpayers in a tax appeal before the Court of Appeal of Québec in proceedings against Revenu Québec, concerning the qualification of a tax shelter.
TRAXXALL Technologies Ltd., 2021
Acted as Canadian special tax counsel to TRAXXALL Technologies Ltd., a significant software-as-a-service solutions provider for aircraft maintenance tracking, in its sale to Jet Support Services, Inc.
Sprott Resource Lending Corp., 2021
Acted as tax counsel to Sprott Resource Lending Corp., as lead arranger for its resource lending investment funds, in the financing of Sabina Gold Corporation’s Goose Gold Mine in the Back River Gold Project located in Nunavut.
Sprott Resource Lending Corp., 2021
Acted as tax counsel to Sprott Resource Lending Corp., as lead arranger for its resource lending investment funds, in the financing (of up to US$100 million) of Geopacific Resource Ltd's Woodlark Gold Project in Papua New Guinea. The financing comprised a project finance facility and a callable gold stream.
Sprott Resource Streaming and Royalty Corp., 2021
Acted as tax counsel for Sprott Resource Streaming and Royalty Corp., as lead arranger for its resource lending investment funds, in its acquisition of the rights under a streaming arrangement with Ascot Resources regarding gold and silver produced by its Red Mountain Project in northwestern British Columbia.
Sprott Resource Lending Corp., 2021
Acted as tax counsel to Sprott Resource Lending Corp., as lead arranger for its resource lending investment funds, in the US$152-million financing of Pure Gold Mining Inc.'s Madsen Gold Project in Red Lake, Ontario. The financing comprised a credit facility and a callable gold stream.
Sprott Resource Lending Corp., 2021
Acted as tax counsel to Sprott Resource Lending Corp., as lead arranger for its resource lending investment funds, in a convertible senior financing in support of SRG Mining Inc.'s bid for North American Lithium Inc., an industrial minerals mining company located in Abitibi, Québec.
Sprott Resource Streaming and Royalty Corp., 2021
Acted as tax counsel to Sprott Resource Streaming and Royalty Corp. in its streaming transaction with West Vault Mining Inc. regarding gold and silver produced by the Hasbrouck Gold Project located in Nevada.
Sprott Resource Lending Corp., 2021
Acted as tax counsel to Sprott Resource Lending Corp., as lead arranger for its resource lending investment funds, in the financing (of up to US$25 million) of Elemental Royalties' acquisition of a portfolio of precious metal royalties from a wholly owned subsidiary of South32 Limited.
Sprott Resource Lending Corp., 2021
Acted as tax counsel to Sprott Resource Lending Corp., as lead arranger for its resource lending investment funds, in the financing (of up to US$105 million) of Ascot Resources Ltd.'s Premier Gold Project in northern British Columbia. The terms of the financing included a senior credit facility, a convertible credit facility and a production payment agreement.
Sprott Resource Lending Corp., 2021
Acted as tax counsel to Sprott Resource Lending Corp., as lead arranger for its resource lending investment funds, in the financing (of up to US$60 million) of Novo Resources Corp.'s Beatons Creek Conglomerate Gold Project in Western Australia.
Sprott Resource Lending Corp., 2021
Acted as tax counsel to Sprott Resource Lending Corp., as lead arranger for its resource lending investment funds, in the financing (of up to US$140 million) of Mudrick Capital Acquisition Corp.'s acquisition of Hycroft Mining Corp., a world-class gold and silver producing operator located in Nevada. The financing comprised a senior credit facility and a net smelter royalty.
Sprott Resource Streaming and Royalty Corp., 2021
Acted as tax counsel to Sprott Resource Streaming and Royalty Corp. in its US$15-million streaming transaction with Cerrado Gold Inc. regarding gold and silver produced by the Don Nicolas mine in the Province of Santa Cruz, Argentina. The stream deposit was used in the financing of Cerrado's acquisition of the Don Nicolas mine.
Sprott Private Resource Lending (Collector), LP, 2021
Acted as tax counsel to Sprott Private Resource Lending (Collector), LP and its subsidiaries in their acquisition under the Companies' Creditors Arrangement Act and disposition of certain gold properties located in Nova Scotia to Aurelius Minerals Inc. and the concurrent equity investment in Aurelius Minerals Inc.
Sprott Resource Lending Corp., 2021
Acted as tax counsel to Sprott Resource Lending Corp., as lead arranger for its resource lending investment funds, in the acquisition of a convertible senior financing in support of Rubicon Minerals Corporation's Bateman Gold Project near Red Lake, Ontario.
Knight Therapeutics Inc., 2021
Acting for Knight Therapeutics Inc. in its dispute before the Tax Court of Canada with respect to the application of Canada's foreign accrual property income regime.
Professional athletes, 2021
Acting for professional athletes in their disputes before the Tax Court of Canada against the Canada Revenue Agency with respect to the correct manner in which their taxable income earned in Canada is to be computed under the Income Tax Act.
Sprott Resource Lending Corp., 2021
Acted as tax counsel to Sprott Resource Lending Corp., as lead arranger for its resource lending investment funds, in the financing (of up to US$160 million) of TMAC Resources Inc.'s Hope Bay Project in the Kitikmeot region of Nunavut.
Warner Media, LLC, 2020
Acted for Warner Media, LLC in its indirect acquisition, by way of plan of arrangement, of all of the issued and outstanding shares of You i Labs Inc., a leading provider of cross-platform development tools for television and media companies.
Granite Real Estate Investment Trust, 2020
Acted as tax counsel to Granite REIT in its $500-million bond offering of 2.378% Series 5 senior unsecured debentures.
Hypertec Infrastructures Inc., 2020
Acted as lead tax counsel for Hypertec Infrastructures Inc. in the sale of its data center and colocation services business to Vantage Data Centers, one of the world's leading hyperscale data center providers.
Granite Real Estate Investment Trust, 2020
Acted as tax counsel to Granite REIT in its $288-million bought deal equity offering of 3.84 million stapled units.
Consolidated Bottle Corporation, 2020
Acted as tax counsel for Consolidated Bottle Corporation, a leading Canadian-based packaging supplier, and its shareholders in its acquisition by Berlin Packaging, the world's largest hybrid packaging supplier.
Connor, Clark & Lunn Infrastructure Ltd., 2020
Acted as tax counsel to Connor, Clark & Lunn Infrastructure Ltd. in its acquisition of USA Rail, an operator of short-line rail terminals in Louisiana and Texas.
Gotham Green Partners, LLC, 2020
Acting as special tax and insolvency counsel for Gotham Green Partners, LLC, a New York-based private equity firm focused on global cannabis and cannabis-related enterprises, in the first successful restructuring of a Canadian cannabis company, iAnthus Capital Holdings, Inc., by way of a corporate plan of arrangement.
Management Shareholders of Give & Go, 2020
Acted for the Management Shareholders of Give & Go, a market leader in the North American bakery industry, in the sale by Thomas H. Lee Partners, L.P., of a significant majority interest in Give & Go to Mondelez International.
NDT Global Corporate, 2020
Acted as Canadian tax counsel to Ireland-headquartered NDT Global, a leading supplier of ultrasonic pipeline inspection and data analysis, on its sale to Caisse de dépôt et placement du Québec/Novacap-backed Eddyfi Technologies, a Québec-based innovative private test & measurement technology group focused on non-destructive testing (NDT).
Groupe Latécoère, 2020
Acted for Groupe Latécoère, a portfolio company of Searchlight Capital Partners, in its acquisition from Bombardier Inc. and certain of its affiliates of the assets relating to electrical wiring interconnection activities for the production of main and sub-electrical harnesses for commercial and business aviation programs.
Glencore Canada Corporation, 2020
Acted for Glencore Canada Corporation in multiple appeals under the Mining Tax Act, RSO, 1990, c M. 15, before the Superior Court of Justice.
Sprott Resource Streaming and Royalty Corp., 2020
Acted as tax counsel for Sprott Resource Streaming and Royalty Corp., as lead arranger for its resource lending investment funds and other institutional investors, in its acquisition of the rights under a US$73.3-million streaming arrangement from Vale S.A. regarding cobalt produced by the Voisey’s Bay Mine in Newfoundland and Labrador.
Claridge Inc., 2020
Acted for Claridge Inc. in the formation and fundraising of Claridge Israel II L.P. in partnership with the Caisse de dépôt et placement du Québec. Claridge Israel II L.P. is a private equity fund that makes growth investments in Israeli-related technology or technology-enabled companies.
Granite Real Estate Investment Trust, 2020
Acted as tax counsel to Granite REIT in its inaugural $500-million green bond offering of senior unsecured debentures.
Granite Real Estate Investment Trust, 2020
Acted as tax counsel to Granite REIT in its $289-million bought deal equity offering of 4.3 million stapled units.
Sprott Resource Lending Corp., 2020
Acted as tax counsel to Sprott Resource Lending Corp., as lead arranger for its resource lending investment funds, in the financing (of up to US$160 million) of Emerald Resources NL's Okvau Gold Project, which is expected to be the first modern large-scale gold project in Cambodia. The financing comprised a senior credit facility and gold price derivatives.
Apotex Inc., 2020
Acted as lead transaction and tax counsel to Apotex Inc. and ApoPharma USA Inc. on the sale of the ApoPharma business, including the global rights to Deferiprone, an iron chelator used to treat iron overload conditions resulting from blood transfusions, to Chiesi Farmaceutici S.p.A.
Confidential client, 2020
Representing a high-net-worth individual before the Tax Court of Canada in a dispute involving foreign exchange forward contracts in what is commonly referred to as "straddle" trading.
Granite Real Estate Investment Trust, 2019
Acted as tax counsel to Granite REIT in its $294-million bought deal equity offering of 4.6 million stapled units.
The Blackstone Group Inc., 2019
Acted for real estate funds managed by The Blackstone Group Inc. and their affiliates in Blackstone's $6.2-billion all-cash acquisition of Dream Global Real Estate Investment Trust and the separation of its external asset manager, Dream Asset Management.
Cadillac Fairview Corporation Limited, 2019
Acted for Cadillac Fairview in its acquisition from First Gulf and its partners of one of the largest planned commercial developments in Canada, the 38-acre East Harbour project in downtown Toronto.
Granite Real Estate Investment Trust, 2019
Acted as tax counsel to Granite REIT in its $231-million bought deal equity offering of 3.7 million stapled units.
Valmet Technologies and Services Inc., 2019
Acted as Canadian counsel to Valmet Technologies and Services Inc. in its acquisition of all the issued and outstanding shares of GL&V Canada Inc., a global provider of technologies and services to the pulp and paper industry.
Barrick Gold Corporation, 2019
Acted for Barrick Gold Corporation in its historic joint venture with Newmont Mining Corporation, which combined their respective mining operations, assets, reserves and talent in Nevada to create the world's largest gold complex.
Nutrien Ltd., 2019
Acted as Canadian tax counsel to Nutrien Ltd. in its acquisition, for a purchase price of over A$468 million by way of a scheme of arrangement under Australian law, of Ruralco Holdings Limited, which is listed on the Australian Securities Exchange (ASX: RHL) and is one of Australia's leading agriservice businesses.
Nutrien Ltd., 2019
Acted as Canadian tax counsel to Nutrien Ltd. in its acquisition of Actagro, LLC, a leading developer, manufacturer and marketer of environmentally sustainable soil and plant health products and technologies.
Fortis Inc., 2019
Acted for Fortis Inc. in the sale of its 51% interest in the Waneta Expansion hydroelectric generating facility in British Columbia to Columbia Basin Trust and Columbia Power Corporation for approximately $1 billion.
James MacDonald, 2019
Acted for Mr. James S.A. MacDonald on his tax appeal on the characterization of payments made under a cash settled forward contract to the Supreme Court of Canada, which granted leave to appeal the decision of the Federal Court of Appeal in the only income tax case heard by the Court in 2019.
Confidential Clients, 2019
Acting for various confidential clients in the context of penal prosecutions under tax Acts.
Beauward Real Estate inc., Schokbeton Québec Inc. and Saramac, 2019
Acted successfully for Beauward Real Estate inc., Schokbeton Québec Inc. and Saramac before the Superior Court of Québec, the Court of Appeal of Québec and the Supreme Court of Canada on a challenge of search warrants and production orders issued by a judge and executed in multiple locations by the Québec Revenue Agency as part of the Permanent Anti-Corruption Unit of Québec.
National Bank of Canada, 2019
Successfully represented National Bank of Canada before the Court of Québec in proceedings against Revenu Québec, concerning the computation of the tax on capital as it applied to financial institutions during the relevant period.
Explorance Inc., 2018
Acted for Explorance in its acquisition, as well as the financing of the acquisition, from Gartner, Inc., of Metrics That Matter, a leading provider of learning and development data and analytics solutions for the corporate market.
Power Energy Eagle Creek, LLP, 2018
Acted for a joint venture of Power Energy Corporation, a subsidiary of Power Corporation of Canada, and Claridge Inc. in the sale of their majority interest in Eagle Creek Renewable Energy, LLC, an operator of 63 hydropower facilities in the United States, representing 216 MW of capacity.
Nutrien Ltd., 2018
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.
Apotex International Inc., 2018
Acted as tax counsel to Apotex International Inc. in the sale of its commercial operations and certain supporting infrastructure for its generics business in five European countries to Aurobindo Pharma Limited.
Forterra Inc., 2018
Acted for Forterra Inc., a leading manufacturer of water and drainage infrastructure pipe and products in the United States and Eastern Canada, as M&A and real estate counsel in the acquisition of three Canadian properties. This acquisition was part of a bigger transaction involving the swap of a number of Canadian and American properties.
Nutrien Ltd., 2018
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.
Gotham Green Partners, LLC, 2018
Acted as special tax and insolvency counsel for Gotham Green Partners, LLC, a New York-based private equity firm focused on global cannabis and cannabis-related enterprises, with respect to in its US$50-million investment in iAnthus Capital Holdings, Inc. (iAnthus), consisting of shares and warrants of iAnthus and high-yield senior secured notes of a subsidiary of iAnthus, which are exchangeable for shares of iAnthus. iAnthus owns, operates and partners with licensed cannabis operations throughout the United States.
Mierins Automotive Group, 2018
Acted as tax counsel for Mierins Automotive Group in the sale of 10 automotive dealerships operating in Ottawa, Kingston and Brockville.
Fortis Inc., 2018
Acted for Fortis Inc. in its $500-million at-the-market public offering of common shares, which will be sold through the Toronto Stock Exchange, the New York Stock Exchange or on any other marketplace in Canada or the United States on which the common shares are traded.
Nutrien Ltd., 2018
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.
Ivanhoé Cambridge Inc., 2018
Acted for Ivanhoé Cambridge Inc., a subsidiary of Caisse de dépôt et placement du Québec, in completing the all-cash acquisition of Pure Industrial Real Estate Trust (PIRET) for $8.10 per unit in a transaction valued at $3.8 billion including debt. Affiliates of Blackstone Property Partners and Ivanhoé Cambridge Inc. acquired 62% and 38% of PIRET, respectively. PIRET owns and operates a diversified portfolio of income-producing properties in leading markets across Canada and key distribution and logistics markets in the United States.
Granite Real Estate Investment Trust, 2018
Acted as tax counsel to Granite REIT in its sale of a real estate portfolio in the United States and Canada for $400 million.
George Markou et al., 2018
Acted for George Markou and a group of over 250 taxpayers before the Supreme Court of Canada (leave application), Federal Court of Appeal and the Tax Court of Canada in a matter relating to charitable donations made between 2001 and 2003 to the John McKellar Charitable Foundation, for which donation tax credits have been denied by the Canada Revenue Agency. The case has generated a number of derivative and interlocutory actions before the Tax Court of Canada and the Federal Court.
Recochem, Inc., 2018
Acted for management of Recochem, Inc., a global leader in manufacturing, marketing and distributing aftermarket transportation and household fluids, in the acquisition of Recochem by an affiliate of H.I.G. Capital, a private equity investment firm from an affiliate of Swander Pace Capital.
A group of investors, 2018
Acted for a group of investors regarding MPX Bioceutical Corporation's issuance, through a wholly owned Luxembourg subsidiary, of US$40 million in secured convertible original issue discount notes.
Canada Life Company, 2018
Acted as counsel to Canada Life in a significant appeal argued recently in the Court of Appeal for Ontario concerning the proposed rectification of a complex corporate transaction that gave rise to an unintended tax liability measured in the tens of millions of dollars. The appeal is under reserve.
Hillcore Financial Corporation, 2018
Acting for Hillcore Financial Corporation and related entities (the Taxpayers) in their dispute before the Tax Court of Canada with respect to trading in foreign exchange derivative contracts and other related disputes.
The Cronos Group Inc., 2017
Acted as tax counsel for The Cronos Group Inc. in the creation of Indigenous Roots, a first-of-its-kind joint venture that works with Canadian First Nations to build and operate licensed facilities and to provide medical cannabis to First Nations patients.
BNP Paribas S.A., 2017
Acted for BNP Paribas S.A. in connection with an investment by the Caisse de dépôt et placement du Québec in Innocap Investment Management Inc.
Airbus SE, 2017
Acted as co-counsel to Airbus SE, a European leader providing tanker, combat and transport aircraft, as well as a global leader in aeronautic, space and related services, in its divestiture of Vector Aerospace Holding SAS to StandardAero Aviation Holdings, Inc.
The Cronos Group Inc., 2017
Provided tax advice to The Cronos Group Inc., a Canadian licensed producer listed on the Toronto Stock Exchange and NASDAQ, in connection with the formation of a strategic joint venture in Israel for the production, manufacture and global distribution of medical cannabis.
Mario Montminy et al., 2017
Successfully represented Mario Montminy and others at the Federal Court of Appeal against the Canada Revenue Agency in a stock option deduction dispute. The court sided with the taxpayers on the eligibility of their deductions.
Claridge Inc., 2017
Acted for Claridge Inc. in connection with its sale to C.H. Guenther & Son, Inc. of Les Plats du Chef, a Canada-based frozen meal and snack business.
PSP Investments, 2017
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.
Ironbridge Equity Partners, 2017
Acted for Ironbridge Equity Partners in connection with its acquisition and related financing of Avena Foods Limited, a leading supplier of gluten-free oats to the North American market.
Atlas Holdings LLC, 2017
Acted for Atlas Holdings in connection with Atlas's acquisition of an 80% equity interest in Millar Western Forest Products and Atlas's exchange of high-yield notes for new secured high-yield notes as the supporting noteholder for Millar Western's US$210-million note exchange transaction. The note exchange transaction was implemented under a plan of arrangement under the Canada Business Corporations Act and, together with Atlas's subsequent equity investment by way of a debt for share exchange transaction, significantly reduced Millar Western's indebtedness and strengthened its financial position, enhancing its ability to respond to and capitalize on developments in the forest products industry.
Fortis Inc., 2017
Acted for Fortis Inc. in connection with its $500-million direct registered offering of common shares to a U.S. institutional investor. The shares were sold pursuant to a cross-border shelf prospectus filed by Fortis under the multi-jurisdictional disclosure system.
Restaurant Brands International Inc., 2017
Acted as Canadian tax counsel to Restaurant Brands International Inc., owner of Burger King and Tim Hortons, in connection with its US$1.8-billion acquisition of Popeyes Louisiana Kitchen, Inc., an Atlanta-based chicken chain.
TIO Networks Corp., 2017
Acted for the Special Committee of the board of directors of TIO Networks Corp., in connection with its $304-million acquisition by PayPal Holdings, Inc. TIO is a North American cloud-based multi-channel bill payment processing and receivables management company.
Sweet Park Holdings Inc., 2017
Acted for The Bensadoun Family Foundation, a principal shareholder of Aritzia Inc., in connection with Aritzia Inc.'s secondary offering of 20,100 million subordinate voting shares at a price of $17.45 per share, for aggregate gross proceeds of $350,745 million, sold via an investment vehicle managed by Berkshire Partners LLC.
Syndicate of underwriters, led by CIBC Capital Markets and RBC Capital Markets, 2017
Acted as Canadian counsel for a syndicate of underwriters, managed by CIBC World Markets Inc., Jefferies Securities, Inc., RBC Dominion Securities Inc. and Robert W. Baird & Co. Incorporated, in connection with the $125-million initial public offering and secondary offering of an aggregate of 10,900,000 Class A subordinate voting shares of Freshii Inc., a Canadian healthy fast-casual franchise. The offering was the first Canadian initial public offering on the Toronto Stock Exchange in 2017.
InstarAGF Asset Management Inc., 2017
Acted for InstarAGF Asset Management Inc. in connection with the formation of InstarAGF Essential Infrastructure Fund with total equity capital commitments of $740 million.
Exiros Canada Inc., 2017
Successfully acted for Exiros Canada in a dispute before the Tax Court of Canada involving transfer pricing.
Confidential Client, 2017
Represented a large Canadian-based international company in the context of (i) a federal criminal investigation on allegations of tax evasion and (ii) a tax investigation.
Mireille Steinberg, 2017
Successfully acted for Mireille Steinberg in a dispute before the Tax Court of Canada in a dispute involving the application of section 94.1 of the Income Tax Act.
Xplornet Communications Inc., 2017
Acted for Xplornet Communications Inc. in its U.S. and Canadian private placement of US$230 million in high yield notes, its US$75 million incremental secured term loan, its repurchase and redemption of existing high yield notes and its associated consent solicitation.
Apotex Holdings Inc., 2017
Acted as tax counsel to Apotex Holdings Inc. in connection with the sale of Accucaps Industries Limited, a developer and manufacturer of over-the-counter pharmaceutical softgels, to Catalent Pharma Solutions.
High-Net-Worth Family, 2017
Acted for a high-net-worth family on tax matters related to a reorganization of the family's corporate holdings.
International Financial Institution, 2017
Advised an international banking and financial group on tax matters related to reporting of foreign accounts.
Investment Fund, 2017
Advised an investment fund on tax matters relating to international investors.
Private Equity Firm, 2017
Representing a private equity group before the Tax Court of Canada in connection with a dispute involving foreign exchange forward contracts in what is commonly referred to as "straddle" trading undertaken by a substantial number of taxpayers.
High-Net-Worth Family, 2017
Advised a high-net-worth family on tax matters related to acquisition of aircraft.
Via Rail Canada Inc., 2017
Acting for Via Rail Canada Inc. in connection with a fuel tax dispute with the Canada Revenue Agency.
