Jennifer Lee

Partner

Jennifer Lee

Jennifer Lee

Partner

Expertise
Bar Admissions
  • New York, 2011

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.

Jennifer Lee

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.

Plusgrade Inc.

Acted for Plusgrade in connection with General Atlantic’s strategic investment in the ancillary revenue powerhouse. The investment represents a monumental transaction for the global travel tech sector.

Ironbridge Equity Partners Management Limited

Acted for funds affiliated with Ironbridge Equity Partners Management Limited in the acquisition and related financing of Gardner Glass Products, Inc., a North Carolina-based company that manufactures and distributes tempered, mirrored, backpainted, and laminated glass products.

ArcTern Partners Inc.

Acted for ArcTern Ventures in the formation of its third flagship fund, ArcTern Ventures Fund III, a US$335 million venture capital fund focused on climate technology companies around the world.

Fortis Inc.

Acted for Fortis Inc. in establishing its at-the-market public offering of up to C$500-million of common shares, which may 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.

Sprott Inc.

Acted for Sprott Inc. in the formation of Sprott Private Resource Streaming and Royalty Annex Fund, a US$310-million annex fund that invests alongside Sprott’s first streaming fund, which brings the combined total assets under management of Sprott Resource Streaming and Royalty Corp. in both funds to US$1.1 billion.

Copper Mountain Mining Corporation

Acted for Copper Mountain Mining Corporation in its US$439-million all-share acquisition by Hudbay Minerals Inc. by way of a court approved plan of arrangement.

Fengate Asset Management Ltd.

Acted for Fengate Asset Management Ltd. in the sale of a 75% interest in the 40 MW Grand Valley III wind project in Ontario to Axium Infrastructure.

Alaris Equity Partners

Acted for Alaris Equity Partners, in its US$546-million investment with Brookfield Special Investments, in Body Contour Centers LLC.

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.

Speaking Engagement

International Fiscal Association, 2024 IFA Canada International Tax Conference, “Worker Mobility - They want to work from where?!”; Montréal, QC

May 14, 2024

Speaking Engagement

Practicing Law Institute, PLI’s International Tax Issues 2024, “Inbound Planning and Developments”; New York

Jan. 30, 2024

Speaking Engagement

Canadian Tax Foundation, 75th Annual Tax Conference, “Limitation of Benefits (LOB)”; Montréal, QC

Nov. 27, 2023

Article

US Corporate AMT: Inbound Investors Beware of Aggregation Rules, co-author

Nov. 15, 2023 - Tax Management International Journal (Bloomberg Industry Group, Inc.) 
Download the article.

Speaking Engagement

Pension Investment Association of Canada, PIAC 2023 Tax Conference, “U.S. Tax Update for Canadian Pension Funds: What’s new and what to look out for?”; Montréal, QC

Nov. 03, 2023

Speaking Engagement

Moderator, International Fiscal Association, 2023 IFA Annual Conference, “Confounding and Unavoidable: Withholding Tax and Other Inbound Topics”; Chicago, IL

Apr. 28, 2023

Bulletin

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...

Bulletin

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...

Speaking Engagement

Practising Law Institute, International Tax Issues 2023, “Planning & Developments”; New York, NY

Jan. 31, 2023

Bulletin

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...

Bulletin

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...

Bulletin

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...

Speaking Engagement

Pension Investment Association of Canada, “Update on U.S. Tax Reform and Proposals”; Webinar

Sept. 23, 2021

Speaking Engagement

Tax Executives Institute, Calgary Chapter, “Back to School – Update on Canada and US Tax”; Webinar

Sept. 16, 2021

Speaking Engagement

American Conference Institute, M&A, RWI and Transactional Risk Insurance Conference, “Tax Liability Insurance,”

Oct. 10, 2018

Article

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)

Bar Admissions

New York, 2011

Education

Columbia University, JD (Harlan Fiske Stone Scholar and James Kent Scholar), 2010
Rice University, BA (magna cum laude), 2006