tax
commodity taxation
estates and trusts
income tax
tax litigation and dispute resolution
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tax

Our Tax Group ranks among the best in Canada and includes individuals who have been recognized internationally as leading advisers in The Martindale-Hubbell Legal Directory and The Canadian Legal LEXPERT Directory. Always sensitive to our clients' business objectives, we provide comprehensive and pragmatic Canadian tax advice on a wide variety of matters, including corporate reorganizations, mergers and acquisitions, securities, structured financing and derivative products, leasing, and cross-border transactions. Routinely advising clients on compliance matters, we are experienced in negotiating disputes with revenue authorities and litigating tax issues.

Our expertise includes:

domestic and international tax planning

 

We are experts in implementing a full range of domestic and cross-border transactions, including mergers and acquisitions, financings, reorganizations and spin-offs. We advise clients on the tax consequences of corporate acquisitions and divestitures, vertical and horizontal amalgamations and wind-ups. Our expertise includes the development of outbound investment structures that permit Canadian residents to repatriate income and gains from foreign investments in a tax efficient manner. We assist domestic and international clients from a wide range of industries in developing transfer pricing methodologies and preparing advance pricing arrangements.

 

tax litigation and dispute resolution

 

Advising at every stage of the dispute process, from audits to administrative appeals and court challenges, our tax dispute settlement team brings together expertise in tax administration, court procedure, substantive tax law and tax policy. Our tax litigators are advocates as well as highly experienced practitioners with broad litigation experience gained from appearing in all levels of Canadian courts.

 

GST/HST, sales and commodity taxes

 

We represent clients with issues involving all types of commodity taxes, including Goods and Services Tax, Harmonized Sales Tax, Quebec Sales Tax, provincial retail sales taxes, federal excise taxes and duties, as well as provincial motor fuels and tobacco taxes.

 

customs and domestic trade remedies

 

We assist in minimizing Canadian customs duties and in securing duty relief, recovery, refunds and deferrals. We apply our expertise in pursuing domestic trade remedies for domestic and foreign producers, exporters, importers and other interested parties in all aspects of anti-dumping, subsidy countervail and safeguard proceedings.

 

charities and not-for-profit entities

 

We assist in establishing not-for-profit entities and obtaining status as registered charities in Canada. With a view to maintaining charitable or non-profit status under the Income Tax Act, we advise these organizations on corporate/commercial issues, governance matters and regulatory and compliance issues.

 

trusts, estates and succession planning

 

We offer comprehensive advice and expertise to address all aspects of effective estate planning. Our full range of wealth transfer solutions includes business and personal succession planning, will and probate planning, trust and estate administration, intergenerational wealth transfer strategies and domestic and international trusts.




Publications / Presentations
March 2012
budget 2012: flexibility for eligible dividend designations introduced
tax bulletin
March 2012
budget 2012: changes to the taxation of resource industries
tax bulletin
March 2012
budget 2012: tightening of the "thin capitalization" rules unveiled
tax bulletin
March 2012
budget 2012: transfer pricing amendments proposed
tax bulletin
March 2012
budget 2012: changes to the tax rules for partnerships
tax bulletin
March 2012
budget 2012: expansion of "prohibited investment" and "advantage" rules to retirement compensation arrangements ("RCAs")
tax bulletin
March 2012
budget 2012: new "foreign affiliate dumping" measures introduced
tax bulletin
March 2012
Ontario budget 2012: an indication of things to come
tax bulletin
January 2012
CRA extends transition period for treaty eligibility forms
tax bulletin
November 2011
proposed legislative amendments shore up safe harbour for non-resident investment funds
tax bulletin
October 2011
further changes to new RRSP/RRIF anti-avoidance rules introduced
tax bulletin
October 2011
A Matter of Fairness: Cancellation of Interest and Penalties under the Canadian Taxpayer Relief Provisions
IBFD - Bulletin for International Taxation
September 2011
Securing & Sustaining "Mutual Fund Trust" Status – Tips & Traps
Portfolio Management Association of Canada Seminar
August 2011
BC HST referendum
tax bulletin
June 2011
Canada Revenue Agency provides list of exempt and taxable health care service providers
Tax Bulletin
June 2011
'new' Canadian treaty eligibility forms – implication for cross border derivatives agreements
Banking Bulletin
June 01, 2011
CRA Releases "New" Treaty Eligibility Forms – Are there New Compliance Obligations to be Met Before Applying a Treaty Reduced Rate of Withholding Tax?
Tax Bulletin
March 2011
budget 2011: proposed changes target abuse of RRSPs and RRIFs
Tax Bulletin
March 2011
budget 2011: accelerated capital cost allowance for the M&P and clean energy sectors
Tax Bulletin
March 2011
budget 2011: partnership deferral benefits eliminated
Tax Bulletin
March 2011
budget 2011 – significant tax measures affecting the charitable sector
Tax Bulletin
March 2011
budget 2011: extension of the super flow-through share program
Tax Bulletin
October 2010
U.S. Tax-Exempts and Article XXI of the Canada-U.S. Treaty: Claiming an Exemption from Canadian Withholding Tax
Journal of International Taxation, Volume 21, No. 10
Co-authored by Michael Friedman and Ashley Palmer
2009
The P Factor: The Puzzling Predicament Posed by Problematic Penalty Provisions – Are Non-Resident Corporations That Late-File Nil Returns Subject to Penalties
Canadian Tax Journal 2009, Volume 57, No 4, p. 871.


Peter Botz
604.893.2319
Jennifer Ann Ward
613.232.7171 Ext. 109
Andrew Etcovitch
514.987.5064