Apotex Pharmaceutical Holdings Inc.

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.

Estate Trustees of Barry Sherman and Honey Sherman

Acted as counsel to Estate Trustees of Barry and Honey Sherman in proceedings against the Toronto Star involving a request to unseal court files concerning the Shermans’ Estates. The precedent-setting decision by the Supreme Court of Canada in this case created new and important law concerning privacy and court openness.

SmartREIT

Acted as tax counsel to a major unitholder of OneREIT, in its $1.1-billion acquisition by SmartREIT and Strathallen Acquisitions Inc. Davies also acted for SmartREIT in this acquisition on corporate and real estate matters.

Atlas Holdings LLC

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.

Viking Air Limited

Acted for Viking Air Limited in connection with its acquisition of the worldwide amphibious aircraft (CL-415 waterbomber) program from Bombardier, including the Type Certificates (manufacturing rights) for all variants of the waterbomber aircraft, and the after-market product support business.

Shaw Communications Inc.

Acted for Shaw Communications Inc. in connection with its sale of Shaw Media Inc. to Corus Entertainment Inc. for $2.65 billion. Shaw Media is the owner of the Global Television Network and 19 specialty channels including HGTV Canada, Food Network Canada and Showcase. Davies acted for Shaw in 2010 on the purchase of these assets from CanWest Global Communications for $2 billion. The proceeds from this sale were used to finance Shaw's acquisition of WIND Mobile for $1.6 billion. Davies acted for WIND Mobile.

Government of Canada

Acted for the Government of Canada in connection with the restructuring of the Nuclear Laboratories division of Atomic Energy of Canada Limited (a federal Crown corporation), including (i) the structuring and development of a competitive procurement process for a private sector contractor that will be responsible for the management and operation of AECL's sites, facilities and assets and the performance of AECL's nuclear decommissioning and waste management responsibilities, operating under a government-owned, contractor-operated (GoCo) model, and (ii) the drafting of the principal procurement and transaction documents, including the Request for Proposal and the management and operating agreements.

Waterton Global Resource Management, Inc.

Acted for Waterton Global Resource Management, Inc. in its sale of the Getchell gold project in Nevada to Premier Gold Mines Limited for consideration of up to US$85 million.

First Quality Enterprises, Inc.

Acted as Canadian counsel to First Quality Enterprises, Inc., and its affiliates in connection with the acquisition of Fempro I Inc. and related companies.

Forest Resources LLC

Acted for Atlas Holdings LLC and Forest Resources LLC in connection with the sale of their Canadian operations, consisting of CanAmPac, Boehmer Box, and Strathcona Paper, to Rosmar Litho, a subsidiary of PaperWorks.

Waterton Global Resource Management

Acted as Canadian tax counsel to Waterton Global Resource Management in connection with the launch of its third private equity fund, Waterton Parallel Fund, with total capital commitments of US$725 million.

USKAL Corporation LLC and the Serruya Family

Acted as tax counsel to USKAL Corporation LLC and the Serruya Family in connection with the sale of Kahala Brands, Ltd., which operates 18 brands at 2,800 fast-food locations in 27 countries, to MTY Food Group Inc. for US$310 million.

Beringer Capital

Acted for Beringer Capital in connection with its acquisition of AdWeek.

Meta Investments

Acted for co-lead investor Meta Investments in the US$90-million Series B investment in Sygnum, a digital asset technology group with a Swiss banking license and a Singapore asset management licence.

TRAXXALL Technologies Ltd.

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.

Mondo Products Company Limited

Acted for the selling shareholder in connection with the sale of Mondo Products Company Limited, the leading car wash cleaning fluids, service and equipment supplier in Canada, to National Carwash Solutions (NCS).

Beattie Pet Hospitals

Acted for Beattie Pet Hospitals in the sale of substantially all of their assets to National Veterinary Associates, which consists of five veterinary clinics located in Ancaster, Burlington, Stoney Creek, Brantford and Hamilton.

Serruya Private Equity

Acting for Serruya Private Equity in connection with the backstopped US$100-million equity investment in MedMen Enterprises Inc., a premier U.S. cannabis retailer.

Wexford Capital LP

Acting for Wexford Capital LP, the largest shareholder of Bonterra Resources Inc., in Bonterra's $17.5 million brokered private placement of common shares and flow-through shares.

Waterton Global Resource Management LP

Acted for Waterton Global Resource Management LP in its sale to Galane Gold Ltd. of the Summit Mine and the infrastructure constituting the Banner Mill in New Mexico from Pyramid Peak Mining, LLC, a wholly owned subsidiary of Waterton.

Affiliates of Sherfam Inc.

Acting for affiliates of Sherfam Inc. in their indirect sale to Red Pine Exploration Inc. of their interest in the Wawa Gold Project in Ontario for consideration of $12.6 million.

Waterton Global Resource Management LP

Acted for Waterton Global Resource Management LP in the sale of Nevada properties from Clover Nevada LLC to Millennial Silver Corp. and the resulting business combination to form Millennial Precious Metals Corp.

Wexford Capital LP

Acted for Wexford Capital LP in Bonterra Resources' $15 million private placement of common shares.

Consolidated Bottle Corporation

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.

Wexford Capital LP

Acted for Wexford Capital LP, the largest shareholder of Mako Mining Corp., in Mako's $12 million bought deal private placement of units and concurrent $16.4 million non-brokered private placement to funds managed by Wexford.

Wexford Capital LP

Acted for Wexford Capital LP, the largest shareholder of Sailfish Royalty Corp., in Sailfish's $18-million rights offering of common shares and the related standby commitment by affiliates of Wexford.

Square, Inc.

Acted as Canadian counsel to Square, Inc. in its acquisition of Dessa, a Toronto-based company building machine learning applications that address significant real-world challenges for all types of businesses.

Apotex Inc.

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.

James MacDonald

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.

Wexford Capital LP

Acted for Wexford Capital LP, the majority shareholder of Sailfish Royalty Corp., in Sailfish's proposed acquisition of Terraco Gold Corp. pursuant to a plan of arrangement under the Business Corporations Act (British Columbia) and the related 19.9% private placement by Wexford into Terraco.

Wexford Capital LP

Acted for Wexford Capital LP, the largest shareholder of Mako Mining Corp., in Mako's $27-million rights offering of common shares and the related standby commitment by an affiliate of Wexford.

Shaw Communications Inc.

Acted for Shaw Communications Inc. in a $548-million secondary bought deal offering of 80,630,383 Class B non-voting participating shares of Corus Entertainment Inc.

Spring Lane Capital

Acting as counsel to Spring Lane Capital in the formation of its inaugural private equity fund formed to invest in sustainability projects in the energy, water, food and waste industries.

Management Systems Resources Inc.

Acted for Management Systems Resources Inc., a leading provider of automated global trade compliance software solutions, in the sale of the Visual Compliance and eCustoms business to Descartes Systems Group for $330 million.

Apotex International Inc.

Acted as tax counsel to Apotex International Inc. in the merger of its Australian and New Zealand generic pharmaceutical and over-the-counter operations with Arrow Pharmaceuticals, the Australian operating business of Strides Ltd., creating Australia's largest generic pharmaceutical and private label OTC business, Arrotex Australia Group.

DPS Capital Inc.

Acting for DPS Capital Inc. with the restructuring of Parkwood Limited Partnership Fund as a feeder fund, investing substantially all of its capital in a Cayman Islands master fund.

Leonardo Worldwide Corporation

Acted for Leonardo Worldwide Corporation, a leading provider of digital asset management and digital marketing solutions for the global hospitality industry, on its sale to Jonas Software.

Wexford Capital LP

Acted for Wexford Capital LP, the majority shareholder of Marlin Gold Mining Ltd., in a business combination transaction between Marlin and Golden Reign Resources Ltd. to form Mako Mining Corp. pursuant to a plan of arrangement under the Business Corporations Act (British Columbia) and a related reorganization of Marlin's assets.

Apotex International Inc.

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.

TD Securities Inc., CIBC World Markets Inc. and Desjardins Securities Inc.

Acted for a syndicate of agents, led by TD Securities Inc., CIBC World Markets Inc. and Desjardins Securities Inc., in a private placement of an additional $75-million senior unsecured Series B notes due June 1, 2021, issued by Crombie Real Estate Investment Trust.

Blue Wolf Capital Partners

Acted as Canadian counsel to Blue Wolf Capital Partners in the US$258-million sale to Conifex Timber Inc. of the Suwannee Sawmill in Florida and the Caddo River Sawmill in Arkansas. The purchase price for the sawmills was satisfied, in part, by the issuance of 9,898,461 million common shares of Conifex and 3,500,000 million warrants.

tZERO.com, subsidiary of Overstock.com

Acting as Canadian counsel for tZERO.com, the financial technology subsidiary of Overstock.com, in its USD$250-million offering of security tokens using blockchain technology by way of a Simple Agreement for Future Equity (SAFE).

Golden Ventures

Acted for Golden Ventures in connection with the formation of its third fund, Golden Ventures III, a leading seed-stage venture capital fund investing across North America.

BlueCat Networks, Inc.

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

20 VIC Management Inc.

Acted for the shareholders of 20 VIC Management Inc., one of Canada's leading commercial real estate management firms, in the sale of 20 VIC to Cushman & Wakefield.

Beringer Capital

Acted for Beringer Capital in connection with the acquisition of iCiDIGITAL, a digital consulting firm.

Beringer Capital

Acted for Beringer Capital in connection with the acquisition of Blue Acorn, Inc., an e-commerce design, development, optimization and marketing services company.

Apotex Holdings Inc.

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.

Waterton Global Resource Management

Acted as counsel to Waterton Nevada Splitter, LLC, a wholly owned subsidiary of Waterton Precious Metals Fund II Cayman, LP, in connection with the acquisition of the Mt. Hamilton gold project from Solitario Exploration & Royalty Corp. and Ely Gold & Minerals Inc.

Mitchell Goldhar, SmartCentres and Walmart

Acted for Mitchell Goldhar, SmartCentres and Walmart in connection with the sale of the SmartCentres platform to Calloway REIT for $1.16 billion.

Waterton Global Resource Management

Acted as Canadian counsel to Waterton Global Resource Management in connection with the launch of its second private equity fund, Waterton Precious Metals Fund II, with total capital commitments of US$1.016 billion.

Fiera Axium Infrastructure Canada II L.P.

Acted for Fiera Axium Infrastructure Canada II L.P. on its 2014 acquisition of an equity interest in the Saint-Robert Bellarmin Wind Projects, which sells power to Hydro-Québec Distribution under a 20-year Power Purchase Agreement, from EDF EN Canada Inc.

Apotex Group

Acted for Apotex Group on the acquisition of Cangene Corporation by Emergent BioSolutions Inc. by way of a plan of arrangement for cash consideration of US$222 million.

Confidential Client

Acted for the purchaser of residual interests from Home Trust Company in mortgage pools totalling $662.2 million originated and securitized by Home Trust Company through the NHA Mortgage Backed Securities program sponsored by Canada Mortgage and Housing Corporation.

Iogen Corporation

Acted for Iogen Corporation in the sale of its industrial enzyme business to an affiliate of Novozymes A/S.

The Cadillac Fairview Corporation Limited

Acted for The Cadillac Fairview Corporation Limited in connection with its US$150 million investment in Terranum Corporate Properties, a Colombian commercial property development business.

Shaw Communications Inc.

Acted for Shaw Communications Inc. in connection with the sale by Shaw of Mountain Cablevision, Shaw's cable system in Hamilton, Ontario, to Rogers Communications Inc., an option for Rogers to purchase Shaw's spectrum licenses for advanced wireless service, and the purchase by Shaw of a one-third interest in TVtropolis, a specialty TV network, from Rogers.

Vista Radio Ltd.

Acted for Vista Radio Ltd., a Canadian broadcasting company with operations primarily in Western Canada, in connection with its acquisition of substantially all of the assets of Haliburton Broadcasting Group Inc. Completion of the transaction was subject to CRTC approval.

The Cadillac Fairview Corporation Limited

Acted as Canadian counsel to The Cadillac Fairview Corporation Limited and its affiliates in connection with investments in Brazil, including the $500-million investment in Multiplan Empreendimentos Imobiliários S.A., one of the leading developers, owners and operators of shopping centres in Brazil.

IMC International Metalworking Companies B.V.

Acted as Canadian counsel to IMC International Metalworking Companies B.V. in connection with its contemplated strategic arrangement with Woulfe Mining Corporation and its 100%-owned tungsten/molybdenum South Korean subsidiary, Sangdong Mining Corporation.

Maple Group Acquisition Corporation

Acted for Maple Group Acquisition Corporation (renamed TMX Group Limited), an entity whose shareholders consisted of five of Canada's largest pension funds, four Canadian bank-owned investment dealers, a leading independent broker dealer, Canada's largest financial co-operative group and a leading Canadian-based financial services group, in connection with its $3.8-billion acquisition of each of TMX Group Inc., The Canadian Depository for Securities Limited, Alpha Trading Systems Inc. and Alpha Trading Systems Limited Partnership, resulting in the creation of a new integrated clearing and exchange group. This deal was awarded Deal of the Year in 2012 by Lexpert magazine.

Runnymede Development Corporation Limited

Acted for Runnymede Development Corporation Limited in connection with the sale of a $91-million portfolio of shopping centres to RioCan Real Estate Investment Trust.

Government of Canada

Acted for the Government of Canada, as vendor, in the disposition of Atomic Energy of Canada Ltd.'s Candu reactor commercial division to SNC-Lavalin Group.

Pilot Gold Inc.

Acted for Pilot Gold Inc. in connection with its $25-million bought deal financing.

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.

Fronteer Gold Inc.

Acted for Fronteer Gold Inc. in an auction transaction for the sale of the uranium assets of Aurora Energy Resources Inc., a wholly owned subsidiary of Fronteer Gold, which resulted in the sale to Paladin Energy Ltd. for C$260 million.

West Face Capital Inc.

Acted for West Face Capital Inc., the largest shareholder of UTS Energy Corporation, in connection with the acquisition of UTS and its 20% interest in the Fort Hills oil sands mining project by Total SA in a deal valued at US$1.6 billion and the spin-off of UTS's other assets into SilverBirch Energy Corporation.

Fronteer Gold Inc.

Acted for Fronteer Gold Inc. in its $281-million acquisition of AuEx Ventures Inc. by way of a plan of arrangement, including a "spin-off" of AuEx's exploration properties into a new publicly traded vehicle.

Pattern Energy Group LP

Acted for Pattern Energy Group LP in the establishment of its joint venture with an affiliate of Samsung C&T Corporation. The joint venture was formed to develop and operate up to 2,000 MW of wind power generation projects under the Ontario Feed-in Tariff Program and Samsung's Green Energy Investment Agreement with the Government of Ontario. The Green Energy Investment Agreement represents the largest initiative of its kind in the world. Up to 600 MW of wind turbines will be supplied to the Pattern-Samsung joint venture by Siemens Canada, which built Ontario's first blade factory to meet this demand.

Shaw Communications Inc.

Acted for Shaw Communications Inc. in its $2-billion acquisition through Companies' Creditors Arrangement Act proceedings of the conventional and specialty television business of Canwest Global Communications Corp., now known as Shaw Media.

Agnico Eagle Mines Limited

Acted for Agnico Eagle Mines Limited in its acquisition of Comaplex Minerals Corp.'s Meliadine gold project, by way of a "spin-off" plan of arrangement in which Comaplex shareholders received Agnico-Eagle shares and, except for the largest Comaplex shareholder, shares of Geomark Exploration Ltd., a newly-created company that holds Comaplex's non-Meliadine assets.

Wexford Capital LP

Acted for entities managed by Wexford Capital LP in connection with a private placement of debentures and warrants to purchase shares of Bronco Energy Ltd. as part of Bronco's $24-million offering. Bronco is a public company primarily engaged in the acquisition, exploration, development, and production of conventional heavy oil and in-situ oil sands in Western Canada.

Fiat S.p.A.

Acted as Canadian counsel for Fiat S.p.A. in the purchase of substantially all of Chrysler LLC's operations by a new company formed in alliance with Fiat for approximately US$2 billion in cash and the assumption of certain liabilities under a U.S. restructuring (Chapter 11) and in the related approximately US$7 billion first lien credit facility provided by the United States Department of the Treasury and the approximately $2 billion working capital facility provided by Export Development Canada.

Patheon Inc.

Acted for the Special Committee of Patheon Inc. in its response to a hostile bid made by JLL Partners Inc., valued at US$600 million including highly contentious proceedings before the OSC, and the successful defence in Ontario Superior Court of Justice of an injunction motion and a precedent setting application alleging improper solicitation of proxies by the Special Committee.

Liquidation World Inc.

Acted for the Special Committee of the Board of Directors of Liquidation World Inc. on its completion of a private placement and an acquisition of Talon Merchant Capital, LLC and its affiliate, TCP Co-Investment Partners, LLC.

Patheon Inc.

Acted for Patheon Inc. in the sale of its Niagara-Burlington commercial manufacturing business to Pharmetics Inc.

Creststreet Power & Income Fund LP

Acted for the Special Committee of Creststreet Power & Income Fund LP in connection with its strategic alternatives review process which culminated in the $121.6-million sale of its windpower subsidiaries to an affiliate of FPL Energy, LLC and the distribution of its net assets to unitholders.

Westwind Partners Inc.

Acted for Westwind Partners Inc., a Toronto-based independent investment bank, in its sale to Thomas Weisel Partners Group Inc. in a plan of arrangement transaction valued at approximately $146.7 million.

Robert and Liz Schad

Acted for the founder and controlling shareholder of Husky Injection Molding Systems Ltd. in the $960-million acquisition of the company by Onex Partners II, LP.

Patheon Inc.

Acted for Patheon Inc. in the issuance of US$150 million private placement of convertible preferred shares to JLL Partners and concurrent refinancing of Patheon's North American credit facilities with new US$225 million syndicated credit facilities by JP Morgan Securities Inc. and GE Commercial Finance.

Access Justice Durham

Acted for Access Justice Durham (sponsored by Babcock & Brown, and including PCL Constructors and Johnson Controls), the successful consortium which entered into an agreement to design, build, finance and maintain the Durham Consolidated Courthouse, the first availability payment PPP relating to courthouses in North America and the first project to be completed by Infrastructure Ontario. This project received the 2007 CCPPP Award of Merit for Project Financing.

Minacs Worldwide Inc.

Acted for Minacs Worldwide Inc. in its auction process and the resulting negotiated all-cash takeover bid for Minacs by Transworks Information Systems Ltd. in a transaction valued at $196 million.

Simmons Canada Inc. and SCI Income Trust

Acted for Simmons Canada Inc. and SCI Income Trust in connection with the $136.8-million acquisition by Simmons Bedding Co. of Simmons Canada.

Patheon Inc.

Acted for Patheon Inc., a leading independent provider of pharmaceutical manufacturing and development services, in its new North American credit facilities in the amount of US$290 million with Royal Bank of Canada as sole Administrative Agent and RBC Capital Markets as Lead Arranger and sole Book Runner.

CIBC World Markets, RBC Dominion Securities Inc. and syndicate

Acted for CIBC World Markets, RBC Dominion Securities Inc. and other syndicate members in regard to the First Trust/Highland Capital Floating Rate Income Fund public offering totalling US$185 million.

Masonite International Corporation

Acted for Masonite International Corp. which was acquired by Stile Acquisition Corp. in a transaction valued at $3.1 billion.

Article

New Canadian real estate rules regarding non-resident ownership, co-author

May 01, 2023 - Financier Worldwide, ExpertBriefing
Read the article.

Article

Canada’s Budget Plan Hides Capital Gains, Stock Options Tax Hike, co-author

Apr. 28, 2023 - Bloomberg Tax, Daily Tax Report: International
Read the article.

Bulletin

Federal Budget 2023 – Major Changes for Business and High Net Worth Individuals

Mar. 28, 2023 - On March 28, 2023 (Budget Day), the Honourable Chrystia Freeland, Deputy Prime Minister of Canada and Minister of Finance, delivered the Liberal Party’s federal budget (Budget 2023). Budget 2023 does not change the corporate and personal tax rates under the Income Tax Act (Act). Instead...

Article

Equitable Remedies in Tax Matters: The Elusive Search for Relief, co-author

Dec. 06, 2022 - Tax Disputes in Canada: The Path Forward (Canadian Tax Foundation)
Available for purchase.

Bulletin

Federal Budget 2022: Tax Highlights

Apr. 08, 2022 - On April 7, 2022 (Budget Day), the Honourable Chrystia Freeland, Deputy Prime Minister of Canada and Minister of Finance, delivered the Liberal Party’s federal budget (Budget 2022), the second budget since the start of the COVID-19 pandemic. As part of the Trudeau government’s plan to “grow our...

Article

Canadian Supreme Court Endorses Treaty Shopping Arrangement, co-author

Mar. 09, 2022 - IFC Review
Read the article.

Article

Supreme Court of Canada to Render Treaty Shopping Decision, co-author

May 12, 2021 - IFC Review
Read the article.

Bulletin

2021 Federal Budget: Tax Highlights

Apr. 20, 2021 - The Honourable Chrystia Freeland, Canada’s Deputy Prime Minister and Minister of Finance, delivered the Liberal Party’s first federal budget (Budget 2021) in over two years and the first since the start of the global COVID-19 pandemic. As part of a recovery plan for “jobs, growth and resilience,”...

Article

Canada chapter, co-author

June 15, 2020 - The Corporate Tax Planning Law Review, 2nd ed. (The Law Reviews)

Bulletin

Estate Planning in Turbulent Times

Apr. 29, 2020 - With more than two-thirds of all Canadians self-isolating in a collective effort to flatten the COVID-19 curve of infection, estate planning is one of a number of planning considerations that are top of mind. Regardless of whether individuals already have a plan in place or have yet to commence...

In the News

Elie Roth and Stephen Ruby Discuss Tax Ruling with Canadian Lawyer and The Lawyer’s Daily

Apr. 01, 2020 - Following the Supreme Court of Canada‘s recent ruling in MacDonald v Canada that a taxpayer’s forward contract was a hedge for income tax purposes, Canadian Lawyer and The Lawyer’s Daily spoke to Davies partners Elie Roth and Stephen Ruby, counsel for the appellants, for...

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

2019 Federal Budget: Tax Highlights

Mar. 19, 2019 - Budget 2019 is the last federal budget of the current Liberal government before the upcoming federal election in October 2019. Tax-related measures are intended to advance the government’s stated priority of creating a fair tax system. Proposals include changes to the employee stock option rules,...

Speaking Engagement

International Bar Association, The New Era of Taxation Conference, “Digital economy- legislative challenges and country-specific solutions”; Vienna, Austria; Nov. 29 & 30 2018

Nov. 29, 2018

Speaking Engagement

New York State Bar Association, 14th Annual International Estate Planning Institute, “Canada-US cross-border planning in light of US tax reform”; New York, NY; Mar. 22 & 23 2018

Mar. 22, 2018

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...

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....

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...

Speaking Engagement

Canadian Tax Foundation, 69th Annual Tax Conference, “Rectification, Rescission and Other Equitable Remedies”; Toronto, ON

Nov. 18, 2017

Bulletin

Tax Proposals Target Canadian Business Owners

Aug. 04, 2017 - Although Canadian individuals are already subject to some of the highest tax rates in the world, the Canadian federal government released a discussion paper for consultation on July 18, 2017 which includes proposals that would substantially increase taxes paid by Canadians who carry on business...

Bulletin

Canadian Government Proposes Major Changes to the Taxation of Private Corporations

July 18, 2017 - The Canadian Department of Finance released a discussion paper earlier today on tax planning using private corporations. Included with the paper is draft legislation for a couple of the matters discussed in the paper. Finance has requested comments on the discussion paper by October 2, 2017. ...

Speaking Engagement

STEP Canada, 19th Annual National Conference, “Taxation of Trusts and their Beneficiaries – Rarer Tips and Traps”; Toronto, ON; June 12 & 13 2017

June 12, 2017

Speaking Engagement

The International Academy of Estate and Trust Law (TIAETL), “Welcome Back Stranger: A Global Perspective on the Taxation of Privately Owned Business Entities and Owners”; Chicago, IL

May 01, 2017

Speaking Engagement

Chair, Canadian Tax Foundation, “Estate Planning and Trusts”; Montréal, QC

Apr. 01, 2017

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...

Guide

Canadian Taxation of Trusts, co-author

Dec. 31, 2016 - (Toronto: Canadian Tax Foundation)

Article

Non-Resident Trusts: Selected Interpretive and Planning Issues – Part II, co-author

Dec. 31, 2016 - Canadian Tax Journal, Vol. 64, No. 3

Article

Non-Resident Trusts: Selected Interpretive and Planning Issues – Part I, co-author

Nov. 30, 2016 - Canadian Tax Journal, Vol. 64, No. 2

Article

Welcome Stranger: A Global Perspective on the Taxation of Trusts—Canadian Income Taxation of Trusts and Beneficiaries

Nov. 25, 2016 - Trusts & Trustees, Vol. 23, No. 1, Pg. 88–108

Speaking Engagement

The International Academy of Estate and Trust Law (TIAETL), “Welcome Stranger: A Global Perspective on the Taxation of Trusts – Canadian Taxation of Trusts and Beneficiaries”; Sydney, Australia

May 01, 2016

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...

Article

Powers to Add and Remove Trust Beneficiaries – Part III

Dec. 01, 2015 - Money & Family Law, Issue 30-12

Article

Powers to Add and Remove Trust Beneficiaries – Part II

Nov. 01, 2015 - Money & Family Law, Issue 30-11

Speaking Engagement

The Law Society of Upper Canada, 18th Annual Trusts and Estates Summit, “Subsection 75(2) of the Income Tax Act: Recent Developments”; Toronto, ON

Oct. 07, 2015

Article

Powers to Add and Remove Trust Beneficiaries – Part I

Oct. 01, 2015 - Money & Family Law, Issue 30-10

Speaking Engagement

STEP Canada, 17th Annual National Conference, “How US Tax Issues Affect Canadian Estate Freezes”; Toronto, ON; June 18 & 19, 2015

June 18, 2015

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...

Guide

Cross-Border Outsourcing - Issues, Strategies and Solutions

Dec. 31, 2014 - Cahiers de droit fiscal international, Studies on International Fiscal Law, Volume 99a (Deventer: International Fiscal Association)

Speaking Engagement

The Law Society of Upper Canada, 17th Annual Trusts & Estates Summit, “Tax Issues in Trust Variations”, Toronto, ON

Nov. 03, 2014

Speaking Engagement

Federated Press, 15th Tax Planning for the Wealthy Family, “International Wealth and Tax Planning”; Toronto, ON

Sept. 01, 2014

Guide

Chapter 13: Canadian National Report

Nov. 30, 2013 - Taxation of Companies on Capital Gains on Shares under Domestic Law, EU Law and Tax Treaties, Vol. 10 – EC and International Tax Law Series (Amsterdam: IBFD)

Speaking Engagement

Federated Press, 7th Tax Planning for the International Client, “Non-Resident Trust Planning”; Toronto, ON

Nov. 01, 2013

Speaking Engagement

Canadian Tax Foundation, 2013 Ontario Tax Conference, “Current Issues in Estate and Family Wealth Transfer Planning”; Toronto, ON; Oct. 28 & 29, 2013

Oct. 28, 2013

Speaking Engagement

STEP Canada, 15th Annual National Conference, “Adding and Removing Beneficiaries of a Trust”; Toronto, ON

June 10, 2013

Speaking Engagement

Federated Press, Structuring Foreign Investments Course, “Use of a Netherlands Holding Company”; Toronto, ON

Jan. 01, 2013

Speaking Engagement

Federated Press, 6th Tax Planning for the International Client, “Creating Offshore Structures”; Toronto, ON

Nov. 01, 2012

Speaking Engagement

STEP Ottawa, “21-Year Rule Planning”; Ottawa, ON

Oct. 01, 2012

Speaking Engagement

STEP Canada, 14th Annual National Conference, “21-Year Deemed Disposition Planning”; Toronto, ON

June 11, 2012

Article

Subsection 75(2): Is the CRA's Interpretation Appropriate?

Nov. 01, 2011 - Report of Proceedings of the Sixty-Second Tax Conference, 2010 Conference Report (Canadian Tax Foundation)

Speaking Engagement

Canadian Tax Foundation, annual conference, “Subsection 75(2): Is the CRA’s Interpretation Appropriate?”; Vancouver, BC; Nov. 28 to 30, 2010

Nov. 28, 2010

Speaking Engagement

Osgoode Hall Law School, LLM Program, “Taxation of Trusts & Estates”; Toronto, ON

June 01, 2010

Speaking Engagement

Federated Press, Tax Planning for Migration to or from Canada, “Minimizing Departure Tax: Deemed Dispositions of Property”; Toronto, ON

Nov. 01, 2009

Guide

Fixing Mistakes (And All That Jazz)

Oct. 19, 2009 - 2009 Ontario Tax Conference (Toronto: Canadian Tax Foundation)

Article

The Rule of Reason Doctrine in European Court of Justice Jurisprudence on Direct Taxation

Jan. 01, 2008 - Canadian Tax Journal, Vol. 56, No. 1

Article

Canadian Taxation of Outbound Investment: An Overview

Aug. 01, 2007 - Corporate Business Taxation Monthly (CCH)

Speaking Engagement

Tax Section of the Florida Bar and Florida Institute of CPAs, 25th Annual International Tax Conference, “Recognizing US and Home Country Tax Issues and Coordination for Individuals from Canada, Germany and the UK Investing in the US”; Miami, FL

Jan. 15, 2007

Speaking Engagement

IBC USA,17th Annual International Trust and Tax Planning Summit, “Reporting Requirements: Observing Transparency Standards While Maintaining Privacy”; Coral Gables, FL

Dec. 01, 2006

Speaking Engagement

The Law Society of Upper Canada, People and Money in Motion: Cross-Border Strategies for Advisors and Their High Net Worth Clients, “Outbound Planning”; Toronto, ON

Nov. 01, 2005

Guide

Chapter 6: Investment by Trustees

May 01, 2005 - Widdifield on Executors and Trustees, 6th ed. (Toronto: Carswell)

Article

Anti-Deferral and Anti-Tax Avoidance: New Barbados Protocol Will Limit Treaty Role in Inversions and Elsewhere

Sept. 01, 2004 - Taxation of Global Transactions, Vol. 4, No. 3

Article

Canadian Taxation of Non-Resident Trusts: A Critical Review of Section 94 of the Income Tax Act

Feb. 01, 2004 - Canadian Tax Journal, Vol. 52, No. 2

Guide

Federal Regulation of Charities: A Critical Assessment of Recent Proposals for Legislative and Regulatory Reform

Dec. 31, 2000 - (Toronto: York University Centre for Public Law and Public Policy)