Our Tax Group

Our Tax Group is composed of some 30 professionals throughout Canada having a broad range of experience in the corporate tax, personal tax and estate planning, tax litigation and commodity tax fields.  Our seasoned tax professionals advise and assist clients in domestic and international transactions.

Members of our Tax Group have served in government and private industry tax departments, are active in numerous professional organizations including the Canadian Tax Foundation and the International Fiscal Association, regularly make submissions to government on tax laws, and write and lecture on taxation matters.

Our Services

Our Tax Group provides practical, innovative and proactive tax services to a diverse client base.  These clients include public and private corporations, financial institutions, trust companies, mutual funds, pension funds, owner-operated businesses, individuals, trusts, estates, charitable foundations, accounting firms and foreign enterprises.  Our Tax Group works closely with other members of the firm involved in commercial, financial, real estate, labour, litigation, corporate and wealth management matters.

Our Tax Group offers unique expertise and depth in all areas of corporate, international, personal and commodity taxation and in the tax litigation field and offers the following specialized services:

Corporate Tax Planning

• Mergers and acquisitions
• Demergers and divestitures
• Reorganizations and restructurings
• Corporate loss utilization strategies
• Structured financing transactions
• Derivative products
• Resource taxation
• Mutual fund and pension fund planning
• Taxation of E-commerce transactions
• Tax matters relating to high tech industry
• Employee compensation arrangements
• Partnerships, joint ventures and trusts

International Tax Planning

• Transfer pricing
• Structuring inbound and outbound investments
• Cross-border joint venturing
• Cross-border licensing, financing, holding and insurance structures
• Foreign affiliates, foreign investment entities and foreign reporting rules
• Non-resident withholding tax

Personal Tax Planning

• Transfer of assets and shares to a corporation (tax deferred rollovers)
• Post mortem tax planning
• Transfer of share ownership to employees, family members or other shareholders
• Income splitting and estate freezing
• Compensation of the owner-manager
• Tax deferred retirement plans
• Taxation of professionals
• Maximizing the capital gains exemption
• Shareholder buy-sell arrangements
• Charitable donations and private charitable foundations
• Emigration from and immigration to Canada
• Offshore and domestic trusts

Tax Litigation

• Submissions respecting proposed assessments
• Objections and appeals
• Voluntary disclosures
• Income tax audits and investigations

Commodity Taxation

• Income tax audits and investigations
• GST and provincial sales tax consequences on the sale and purchase of assets
• GST and provincial sales tax consequences on the use of partnerships, trusts and joint ventures
• GST and provincial sales tax on imports and exports
• Tobacco tax
• Fuel tax
• Customs duties and excise taxes

Our Experience

Our Tax Group acts for a diverse client base including Canadian and foreign firms on all relevant tax and trade law questions.  Recently our Tax Group has acted in the following matters:

• Acquisition of Cadillac Fairview Corporation by Ontario Teachers' Pension Plan Board
• Acquisition of Provigo Inc. by Loblaw Companies Limited
• Divestiture of E.B. Eddy Limited by George Weston Limited
• Acquisition of Scott's Restaurants Inc. by SR Acquisition Corporation
• Structuring and implementation of the Mackenzie Income Trust
• Worldwide spin off of Agilent Technologies by Hewlett-Packard
• Divestiture of Trans Canada Pipelines' midstream business