Clients rely on Paul for clear and practical advice on their complex tax issues.
Paul advises leading multinational corporations – both public and private – on their domestic and international tax planning. He has significant expertise in cross-border investment funds, international structuring, public offerings and mergers and acquisitions. Paul also regularly counsels on trust and estate matters, as well as tax disputes with the Canada Revenue Agency.
Paul has lectured on tax in the law faculties of Western University and the University of Toronto.
Acted as Canadian counsel to the initial purchasers, led by Barclays, BMO Capital Markets, Goldman Sachs & Co. LLC, RBC Capital Markets, Scotiabank and CIBC Capital Markets, in the private placement of US$750 million of senior secured notes of GFL Environmental Inc.
BofA Securities, MUFG, Scotiabank and BMO Capital Markets
Acted as Canadian counsel to the initial purchasers, led by BofA Securities, MUFG, Scotiabank and BMO Capital Markets, in the private placement of US$600 million of notes of CCL Industries Inc.
Blackstone Tactical Opportunities
Acted for Blackstone Tactical Opportunities in its US$460-million sale with Orion Resource Partners of the gold prepay, stream facilities and an offtake agreement in respect of Lundin Gold Inc.'s Fruta del Norte mine to Newcrest Mining Limited.
Acted for Digital Colony in connection with the additional $148.5 million of bank financing raised to recapitalize Beanfield Technologies Inc. and the related tuck-in acquisition by Beanfield of the fibre business of Aptum Technologies.
Acted as counsel to SEMAFO Inc. in its US$2.1-billion business combination with Endeavour Mining Corporation by way of plan of arrangement under the Business Corporations Act (Québec).
Rogers Communications Inc.
Acted for Rogers Communications Inc. in its US$1.0-billion public offering of 3.70% senior notes due 2049, issued in the United States under the multijurisdictional disclosure system.
Acted for Digital Colony, the global digital infrastructure investment platform of Colony Capital, Inc., in its acquisition (and related bank financing) of Beanfield Technologies Inc., an independent bandwidth infrastructure provider serving the enterprise, carrier and multi-dwelling unit markets in Toronto and Montréal over its owned fibre network.
Rogers Communications Inc.
Acted for Rogers Communications Inc. in its $1-billion public offering of 3.25% senior notes due 2029, issued in Canada. This offering was supported by the largest single-tranche order book on record in Canada.
Rogers Communications Inc.
Acted for Rogers Communications Inc. in its US$1.25-billion public offering of 4.35% senior notes due 2049, issued in the United States under the multijurisdictional disclosure system.
Barclays, BMO Capital Markets, Macquarie Capital and RBC Capital Markets
Acted as Canadian counsel to the initial purchasers, led by Barclays, BMO Capital Markets, Macquarie Capital and RBC Capital Markets, in the private placement of US$600 million of high-yield notes of GFL Environmental Inc.
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 on May...
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...
Canadian Tax and Other Measures Implemented in Response to COVID-19 Pandemic
Mar. 27, 2020 - Starting on March 18, 2020, the Canadian government has announced a series of emergency measures intended to help stabilize the economy in response to the COVID-19 pandemic. These include tax and economic measures aimed at providing financial support for individuals and businesses, and alleviating...
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...
Taxation of Corporate Reorganizations, 3rd ed., co-author
Mar. 29, 2019 - (Toronto: Carswell)
Purchase a copy of Taxation of Corporate Reorganizations, 3rd ed.
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,...
Tax Court Finds That Broker Fees on a Private Company Sale Were GST/HST-Taxable
May 10, 2018 - The Tax Court of Canada recently released its decision in Barr v. The Queen, 2018 TCC 86, which considered whether share-sale commissions were exempt from HST. The taxpayer was the sole shareholder of a Canadian company. He had retained two brokers for the sale of his company or its...
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...
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...