Glencore Canada Corporation

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.

Sumanic Investments

Acted for Sumanic Investments, the controlling shareholder of Logistec Inc., in the $1.2-billion acquisition of Logistec by Blue Wolf Capital Partners. 

Atlas Holdings LLC

Acted for Atlas Holdings LLC in its acquisition of Resolute FP Canada Inc.'s pulp, newsprint, and directory paper mill operations in Thunder Bay, Ontario. 

BELLUS Health Inc.

Acted for BELLUS Health Inc. in its US$2-billion sale to GSK plc, a British-based pharmaceutical company.

Blackstone Real Estate Income Trust, Inc.

Acted for Blackstone Real Estate Income Trust, Inc. in its acquisition of a portfolio of 12 seniors' housing residences in Québec.

EcoPro BM

Acting for Korea-based EcoPro BM in its C$1.2-billion joint venture with Ford and SK On to build a cathode manufacturing facility to produce electric vehicle (EVs) battery materials in Bécancour, Quebec.

Logiciels Metrio Inc.

Acted for Logiciels Metrio Inc., a Montréal-based ESG reporting and analytics firm, in its sale to Nasdaq, Inc., a global technology company.

Grimco Canada, Inc

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.

Axium Infrastructure Inc.

Acted for Axium Infrastructure Inc. in its acquisition from the Canada Pension Plan Investment Board of a 49% interest in an approximately 396 MW portfolio of four wind generation facilities (Summerhaven, Conestogo, Varna and Jericho) and two solar generation facilities (Sombra and Moore), all located in Ontario.

Professional athletes

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.

Warner Media, LLC

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.

Confidential client

Acted for a confidential client in the metal and mining industries in defence to a request made to the court for the authorization of an administrative seizure.

Family Shareholders of Dorel Industries Inc.

Acting for the controlling family shareholders, who partnered with Cerberus Capital Management, L.P. in the privatization of Dorel Industries Inc., a TSX-listed company, by way of plan of arrangement. 

Confidential client

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.

Trivest Partners L.P.

Acted for Trivest Partners L.P., a U.S. private equity firm focused exclusively on mid-market founder- and family-owned businesses, in its add-on acquisition of Total Power Limited, a Canadian provider of generators and climate control systems operating in Ontario, British Columbia and Alberta. The purchase was financed through various arrangements, including equity contributions and an increase in Trivest's senior secured facility with its bank syndicate.

New Look Vision Group

Acting for New Look Vision Group in its acquisition of substantially all of the assets of Miami-based Coco Lunette Holding, LLC, which carries on business principally under the Edward Beiner banner, a retailer known for its unique and original designer eyewear, with a strong presence in key premium markets across 12 locations in Florida.

Private Equity Firm

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.

J.G. Guy Simard et al.

Acted for Colonel J.G. Guy Simard (retired) and other taxpayers who participated in the "Synergy Program", a program designed to provide funding for start-up businesses, in their dispute before the Tax Court of Canada with the Canada Revenue Agency over the deductibility of related losses. The appeals served as de facto representative cases for approximately 4000 other taxpayers who contested potentially over two hundred million dollars in tax deductions.

The Canadian Bar Association, The Current State of CRA Audits, "OBA Taxation Law Program"; Webcast

Mar. 05, 2024

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

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

Disclosure Requirements Aimed at Shell Companies, co-author

Jan. 24, 2023 - Canadian Tax Journal, Vol. 70, No. 4, (Canadian Tax Foundation)
Download the article.

New Rules and Reporting Requirements Coming for the Real Estate Sector

Dec. 23, 2022 - As 2022 comes to a close, we draw your attention to certain new and proposed legislation that the Canadian federal government has introduced and that will have important implications for Canadian residential real estate and the Canadian real estate sector more broadly. Specifically, we offer...

CRA Goes Digital: New Requirements for Authorization of a Representative and New Procedures relating to Access of Information Requests

Apr. 27, 2022 - Stratège Magazine (APFF) Spring 2022, Vol. 27, No. 1
Download this article (in French).

Tips, Guidance for Navigating Audits of Canada Emergency Wage Subsidy Claims, co-author

June 09, 2021 - The Lawyer’s Daily
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CRA Commences Comprehensive Canada Emergency Wage Subsidy Audits, co-author

June 01, 2021 - The Lawyer’s Daily
Read the article.

Status Quo Restored: Interest Deductibility and the Burden of Proof

May 01, 2021 - Canadian Tax Focus (CTF), Vol. 11, No. 2
Read the article.

Be Prepared: Audits of Canada Emergency Wage Subsidy Claims Underway

Apr. 28, 2021 - A key part of the Canadian government’s response to the COVID-19 pandemic has been the Canada Emergency Wage Subsidy (CEWS). Although the CEWS has undergone a number of changes over the past year, its basic framework has remained the same: a wage subsidy of up to 75% of eligible remuneration...

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,”...

Is a Green New (Tax) Deal Coming to Canada?

Feb. 02, 2021 - In this article originally published in Tax Notes International, Davies lawyers Gregg Benson, Michael Kandev and James Trougakos review Canadian tax incentives for green energy and juxtapose them with those offered by the United States. Download the article.

Canadian Tax Laws: A Review of 2020 and a Look Ahead to 2021

Jan. 28, 2021 - Review of Canadian Tax Developments in 2020 The year 2020 was anything but normal with the global COVID-19 pandemic creating both human and fiscal challenges in Canada and abroad. The federal government’s attention was fixed firmly on the pandemic for most of the year, and it was only in November...

Commentary: Third-Party Litigation Funding May Provide ‘Best of Both Worlds’ Outcome in Tax Disputes, co-author

Sept. 27, 2020 - The Northern Miner
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Deadlines Under Federal Legislation Temporarily Extended Due to COVID-19

Sept. 24, 2020 - Introduction Parliament passed on July 27, 2020, the Time Limits and Other Periods Act (COVID-19) (Time Limits Act), which we summarized in a previous bulletin. Briefly, the Time Limits Act automatically suspends statutory time limits for federal civil proceedings for six months and...

Canada Emergency Wage Subsidy: An Updated Guide for Businesses

Aug. 25, 2020 - The federal government passed legislation on July 27, 2020, extending the Canada Emergency Wage Subsidy (CEWS) and significantly broadening its reach. In this guide, we provide a comprehensive review and analysis of the CEWS program, including details of the latest updates and key considerations...

CEWS Update: Review of New Rules and CRA Guidance

June 09, 2020 - Introduction Earlier this year, Parliament enacted legislation adopting the Canada Emergency Wage Subsidy (CEWS) through amendments to the Income Tax Act (Canada) (Act). We previously reviewed the initial legislation in detail. Read our earlier analysis. In a press release issued...

Canadian Government’s Proposed Extension of Time Limits Due to COVID-19

May 27, 2020 - As part of the federal government’s response to the COVID-19 pandemic, the Department of Finance recently published a draft legislative proposal, the Time Limits and Other Periods Act (COVID-19) (Proposal), that, if implemented, would provide for an automatic six-month suspension of time...

The Canada Emergency Wage Subsidy: A Guide for Businesses

Apr. 23, 2020 - Introduction Parliament has enacted legislation adopting the Canada Emergency Wage Subsidy (CEWS) through amendments to the Income Tax Act (ITA). Although the CEWS program is not tax legislation, by implementing the CEWS through the ITA, the government sought to leverage existing income...

Obscure Canadian Withholding Tax Rule a Trap for the Unwary, co-author

Mar. 09, 2020 - Tax Notes International, Vol. 97, No. 10 (Tax Analysts)
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