Amanda Heale

Amanda Heale, Associate, Taxation

Contact Information

  • tel: 416.862.6780
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Areas of Expertise

Bar Admission

Ontario, 2005

Education

  • University of Toronto, J.D. (Silver Medallist, Dean’s Key Recipient)
  • Queen’s University, B.A.H. (English Literature)

Office

Toronto

Language(s)

English

Biography

Amanda advises on tax issues related to international tax planning, domestic and cross-border mergers and acquisitions, transfer pricing, corporate finance and tax dispute resolution.

In 2004-2005, Amanda was a law clerk to the Honourable Morris J. Fish of the Supreme Court of Canada. Amanda is a member of Osler’s Student Committee.

Notable Matters

  • Canada v. GlaxoSmithKline Inc., 2012 SCC 52, appeal to the Supreme Court regarding the transfer price of the active ingredient in a branded pharmaceutical product.
  • URS Corporation in its $1.5 billion acquisition of Flint Energy Services Ltd.
  • Sterling Partners in its $590 million acquisition of MOSAID Technologies Inc.
  • Equinox Minerals in its unsolicited bid for Lundin Mining and its acquisition agreement with Barrick Gold Corporation.
  • Walter Energy in its $3.3 billion acquisition of Western Coal Corp. by plan of arrangement.
  • Kinross Gold Corporation in its $7 billion acquisition of Red Back Mining Inc.
  • Magna International in its dual class share capital reorganization by way of plan of arrangement.
  • Issuer's counsel on Bank of Montreal’s Covered Bond Programme.
  • Issuer’s counsel on The Bank of Nova Scotia’s Covered Bond Programme.
  • Dealers’ counsel on National Bank of Canada’s Covered Bond Programme.

Affiliations

  • Law Society of Upper Canada
  • Canadian Bar Association
  • Ontario Bar Association
  • Canadian Tax Foundation
  • International Fiscal Association

Publications/Events/Education

  • News Analysis: International Highlights in Canada’s 2013 Budget, Tax Notes International, Volume 70, Number 1, April 1, 2013 (co-authored with Drew Morier, Patrick Marley and Mark Brender).
  • News Analysis: Principal International Tax Changes in Canada’s 2013 Budget, Worldwide Tax Daily, March 26, 2013 (co-authored with Drew Morier, Patrick Marley and Mark Brender).
  • Collins & Aikman Products Co. et al. v. The Queen, Taxation of Corporate Organization and Reorganization, Volume II, Report No. 89 (co-authored with Mark D. Brender).
  • The Estate of the Late Donald Mills v. The Queen, Taxation of Corporate Organization and Reorganization, Volume II. Report No. 88 (with the assistance of Patrick Lupa, Articling Student).
  • CRA Policy Update, Presented at Canadian Tax Foundation Toronto Young Practitioners Group Meeting, October 6, 2010.
  • Recent Proposed Amendments Impact Acquisitions of Control of Canadian Corporations Holding Foreign Affiliates, Acquisition of Control, Corporate Structures and Groups, Volume XXI, No. 1, 2010.
  • Technical Explanation Clarifies Protocol to Canada-US Tax Treaty, Journal of International Taxation, October 2008 (co-authored with Patrick Marley and Drew Morier).
  • Tax Court Rules Non-resident Insurers can Conduct Extensive Business in Canada without Tax Liability, Canadian Current Tax, Volume 18, Number 10, July 2008.
  • New Limitations on Imposition of Interest Withholding Tax, Derivatives and Financial Instruments, March/April 2008 (co-authored with Matias Milet).
  • Foreign Currency Issues Affecting Foreign Affiliates, Council for International Tax Education, Inc., Canadian International Tax Update, May 2008 (co-authored with Patrick Marley).
  • Elimination of Canadian Withholding Tax on Interest Paid to Non-residents, Derivatives Financial Products Report, Volume 9, No. 9, May 2008 (co-authored with Matias Milet).
  • New Foreign Currency Rules: Are They Functional, CCH International Tax Newsletter, Report 37, December 2007 (co-authored with Patrick Marley).
  • Treaty Update, Taxation Law, Taxation Law Section, Volume 18, No. 1, December 2007.
  • Tax authorities take on the treaty shoppers, International Tax Review, December/January 2006 (co-authored).

Downloadable Profile

Amanda Heale