Copper Mountain Mining Corporation
Acting for Copper Mountain Mining Corporation in connection with its US$439-million all-share acquisition by Hudbay Minerals Inc. by way of a court approved plan of arrangement.
Partner
Partner
Clients rely on Jennifer’s strategic and practical advice to optimize their tax structure in cross-border and domestic transactions.
Jennifer focuses on U.S. federal income tax treatment of cross-border and domestic transactions and multinational corporations. She represents foreign pension funds and governmental entities with investments in hedge funds, private equity funds, infrastructure funds, digital asset funds and other private investment vehicles. Jennifer advises public and private acquirers and targets in cross-border and domestic investments, joint ventures, mergers and acquisitions. She also has extensive experience with emerging and high-growth companies in connection with investments by U.S. investors and fund sponsors regarding fund formation matters.
U.S. non-profit and tax-exempt entities benefit from Jennifer’s experienced counsel on formation, securing of tax exemption, governance and operation.
Before joining Davies, Jennifer practised at the New York office of a leading Canadian law firm.
Partner
Clients rely on Jennifer’s strategic and practical advice to optimize their tax structure in cross-border and domestic transactions.
Jennifer focuses on U.S. federal income tax treatment of cross-border and domestic transactions and multinational corporations. She represents foreign pension funds and governmental entities with investments in hedge funds, private equity funds, infrastructure funds, digital asset funds and other private investment vehicles. Jennifer advises public and private acquirers and targets in cross-border and domestic investments, joint ventures, mergers and acquisitions. She also has extensive experience with emerging and high-growth companies in connection with investments by U.S. investors and fund sponsors regarding fund formation matters.
U.S. non-profit and tax-exempt entities benefit from Jennifer’s experienced counsel on formation, securing of tax exemption, governance and operation.
Before joining Davies, Jennifer practised at the New York office of a leading Canadian law firm.
Copper Mountain Mining Corporation
Acting for Copper Mountain Mining Corporation in connection with its US$439-million all-share acquisition by Hudbay Minerals Inc. by way of a court approved plan of arrangement.
Cornerstone Capital Resources Inc.
Acted for Cornerstone Capital Resources Inc. in its merger with SolGold plc under a court-approved plan of arrangement, consolidating ownership of the Cascabel project in northern Ecuador.
Fulcrum Capital Partners
Acted for Fulcrum Capital Partners in the merger of its portfolio company, Accucam Machining, with EQI Ltd., a portfolio company of Atlas Holdings, to create a leading global supply chain solution for metal products.
Barrick Gold Corporation
Acted for Barrick Gold Corporation in the sale of a portfolio of 22 royalties to Maverix Metals for total cash consideration of up to US$60 million, and Nevada Gold Mines in the sale of a portfolio of three royalties to Gold Royalty Corp. for share consideration with a value of US$27.5 million.
AutoCanada Inc.
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.
Fulcrum Capital Partners
Acted for Fulcrum Capital Partners in the sale of Kore Outdoor Inc. to Ironbridge Equity Partners.
Birch Hill Equity Partners
Acted for Birch Hill Equity Partners in its joint acquisition (and related financing) with Investissement Québec of Québec-based Polycor Inc., the largest quarrier of natural stone in the world.
FS Investors
Acted for FS Investors, as lead investor, as well as Fonds de solidarité FTQ, Fondaction, Fonds économie circulaire and MacKinnon, Bennett & Co. in connection with their respective investments in the Montréal green tech company CarbiCrete Inc.
Moderator, International Fiscal Association, 2023 IFA Annual Conference, “Confounding and Unavoidable: Withholding Tax and Other Inbound Topics”; Chicago, IL
Apr. 28, 2023
Federal Courts Weigh in on the FBAR: Providing Relief from Outrageous Penalties
Mar. 22, 2023 - In this bulletin, we highlight two recent federal court cases in which U.S. taxpayers won major victories against the United States with respect to their obligations to report non-U.S. accounts on FinCEN Form 114 – Report of Foreign Bank and Financial Accounts, more commonly referred to...
U.S. Tax Laws: A Review of 2022 and a Look Ahead to 2023
Feb. 21, 2023 - As we settle into the new year, let’s take a moment to first consider last year’s tax developments and then take a look ahead to what 2023 might have in store for us. Review of U.S. Tax Developments in 2022 In 2022 we finally saw some movement on President Biden’s tax policy with the...
Practising Law Institute, International Tax Issues 2023, “Planning & Developments”; New York, NY
Jan. 31, 2023
Upcoming Proposed Regulatory Changes to Stock Buyback Excise Tax
Dec. 29, 2022 - With another new year nearly upon us, we call attention to regulatory changes to the Stock Buyback Excise Tax that will be proposed to take effect on January 1 and the implications on more non-U.S. corporations. Specifically, we address exceptions for (i) a broad new per se funding rule...
U.S. Climate Change and Healthcare Bill Moves Democrats’ Tax Policy Forward
Aug. 18, 2022 - The Inflation Reduction Act of 2022 (Act), which was signed into law on August 16, is intended to fight inflation and address climate change. The Act provides for over $360 billion in energy- and climate-related investments, including the expansion, extension and creation of numerous tax...
U.S. Tax Laws: A Review of 2021 and a Look Ahead to 2022
Mar. 03, 2022 - Review of U.S. Tax Developments in 2021 Last year, we predicted that the biggest U.S. tax news in 2021 would be revenue-raising legislation that the Democrats would put forward after the election of Joe Biden as the 46th president of the United States. As we went to press last year, runoff...
Pension Investment Association of Canada, “Update on U.S. Tax Reform and Proposals”; Webinar
Sept. 23, 2021
Tax Executives Institute, Calgary Chapter, “Back to School – Update on Canada and US Tax”; Webinar
Sept. 16, 2021
American Conference Institute, M&A, RWI and Transactional Risk Insurance Conference, “Tax Liability Insurance,”
Oct. 10, 2018
The Changing Landscape of Affiliated Debt Planning: Post-BEPS/Proposed Section 385 Regulations, co-author
May 19, 2016 - Global Tax Weekly, Issue 184 (Wolters Kluwer)
New York, 2011
Columbia University, JD (Harlan Fiske Stone Scholar and James Kent Scholar), 2010
Rice University, BA (magna cum laude), 2006
Clients rely on Jennifer’s strategic and practical advice to optimize their tax structure in cross-border and domestic transactions.
Jennifer focuses on U.S. federal income tax treatment of cross-border and domestic transactions and multinational corporations. She represents foreign pension funds and governmental entities with investments in hedge funds, private equity funds, infrastructure funds, digital asset funds and other private investment vehicles. Jennifer advises public and private acquirers and targets in cross-border and domestic investments, joint ventures, mergers and acquisitions. She also has extensive experience with emerging and high-growth companies in connection with investments by U.S. investors and fund sponsors regarding fund formation matters.
U.S. non-profit and tax-exempt entities benefit from Jennifer’s experienced counsel on formation, securing of tax exemption, governance and operation.
Before joining Davies, Jennifer practised at the New York office of a leading Canadian law firm.
Copper Mountain Mining Corporation
Acting for Copper Mountain Mining Corporation in connection with its US$439-million all-share acquisition by Hudbay Minerals Inc. by way of a court approved plan of arrangement.
Cornerstone Capital Resources Inc.
Acted for Cornerstone Capital Resources Inc. in its merger with SolGold plc under a court-approved plan of arrangement, consolidating ownership of the Cascabel project in northern Ecuador.
Fulcrum Capital Partners
Acted for Fulcrum Capital Partners in the merger of its portfolio company, Accucam Machining, with EQI Ltd., a portfolio company of Atlas Holdings, to create a leading global supply chain solution for metal products.
Barrick Gold Corporation
Acted for Barrick Gold Corporation in the sale of a portfolio of 22 royalties to Maverix Metals for total cash consideration of up to US$60 million, and Nevada Gold Mines in the sale of a portfolio of three royalties to Gold Royalty Corp. for share consideration with a value of US$27.5 million.
AutoCanada Inc.
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.
Fulcrum Capital Partners
Acted for Fulcrum Capital Partners in the sale of Kore Outdoor Inc. to Ironbridge Equity Partners.
Birch Hill Equity Partners
Acted for Birch Hill Equity Partners in its joint acquisition (and related financing) with Investissement Québec of Québec-based Polycor Inc., the largest quarrier of natural stone in the world.
FS Investors
Acted for FS Investors, as lead investor, as well as Fonds de solidarité FTQ, Fondaction, Fonds économie circulaire and MacKinnon, Bennett & Co. in connection with their respective investments in the Montréal green tech company CarbiCrete Inc.
Moderator, International Fiscal Association, 2023 IFA Annual Conference, “Confounding and Unavoidable: Withholding Tax and Other Inbound Topics”; Chicago, IL
Apr. 28, 2023
Federal Courts Weigh in on the FBAR: Providing Relief from Outrageous Penalties
Mar. 22, 2023 - In this bulletin, we highlight two recent federal court cases in which U.S. taxpayers won major victories against the United States with respect to their obligations to report non-U.S. accounts on FinCEN Form 114 – Report of Foreign Bank and Financial Accounts, more commonly referred to...
U.S. Tax Laws: A Review of 2022 and a Look Ahead to 2023
Feb. 21, 2023 - As we settle into the new year, let’s take a moment to first consider last year’s tax developments and then take a look ahead to what 2023 might have in store for us. Review of U.S. Tax Developments in 2022 In 2022 we finally saw some movement on President Biden’s tax policy with the...
Practising Law Institute, International Tax Issues 2023, “Planning & Developments”; New York, NY
Jan. 31, 2023
Upcoming Proposed Regulatory Changes to Stock Buyback Excise Tax
Dec. 29, 2022 - With another new year nearly upon us, we call attention to regulatory changes to the Stock Buyback Excise Tax that will be proposed to take effect on January 1 and the implications on more non-U.S. corporations. Specifically, we address exceptions for (i) a broad new per se funding rule...
U.S. Climate Change and Healthcare Bill Moves Democrats’ Tax Policy Forward
Aug. 18, 2022 - The Inflation Reduction Act of 2022 (Act), which was signed into law on August 16, is intended to fight inflation and address climate change. The Act provides for over $360 billion in energy- and climate-related investments, including the expansion, extension and creation of numerous tax...
U.S. Tax Laws: A Review of 2021 and a Look Ahead to 2022
Mar. 03, 2022 - Review of U.S. Tax Developments in 2021 Last year, we predicted that the biggest U.S. tax news in 2021 would be revenue-raising legislation that the Democrats would put forward after the election of Joe Biden as the 46th president of the United States. As we went to press last year, runoff...
Pension Investment Association of Canada, “Update on U.S. Tax Reform and Proposals”; Webinar
Sept. 23, 2021
Tax Executives Institute, Calgary Chapter, “Back to School – Update on Canada and US Tax”; Webinar
Sept. 16, 2021
American Conference Institute, M&A, RWI and Transactional Risk Insurance Conference, “Tax Liability Insurance,”
Oct. 10, 2018
The Changing Landscape of Affiliated Debt Planning: Post-BEPS/Proposed Section 385 Regulations, co-author
May 19, 2016 - Global Tax Weekly, Issue 184 (Wolters Kluwer)
New York, 2011
Columbia University, JD (Harlan Fiske Stone Scholar and James Kent Scholar), 2010
Rice University, BA (magna cum laude), 2006
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For general inquiries, contact info@dwpv.com.
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