Matias  Milet

Matias Milet, Partner, Taxation

Contact Information

  • tel: 416.862.6648
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Bar Admission

Ontario, 2005 ; New York, 2000


  • McGill University, LL.B (graduated first in class)
  • York University, M.A




English, French, Spanish


Matias advises on Canadian tax issues associated with cross-border business ventures and transactions, investment funds and pension funds. His practice has included a broad range of transactions and advice to Canadian and international clients involving tax treaties, the taxation of trusts, corporations and partnerships and the taxation of investments in private equity, infrastructure and real estate by pension funds. Matias has taught international tax at the University of Toronto Faculty of Law and is currently a member of the Editorial Board of the Canadian Tax Journal.

Notable Matters

  • Counsel to Manulife Financial Corporation in its $4-billion acquisition of the Canadian-based operations of Standard Life plc. The deal combines Manulife, one of the largest insurance companies in the world, and Standard Life Canada, the country’s fifth-largest insurer.
  • Goldman Sachs & Co in cross-border financial instrument transactions.
  • Goldman Sachs Asset Management in the establishment of Canadian pooled investment funds.
  • Canadian asset manager in a cross-border business restructuring involving delegation of investment management to non-resident sub-advisor.
  • Canadian life insurer in resolving complex and large-scale tax filing error.
  • Oxford Realty Corporation in its purchase of Brookfield Properties Ltd.’s interest in TD Canada Trust Tower.
  • General Electric in internal corporate reorganizations.


  • Law Society of Upper Canada
  • State Bar of New York
  • Canadian Tax Foundation
  • Canadian Bar Association, Ontario

Industry Recognition

  • Douglas Sherbaniuk Distinguished Writing Award, Canadian Tax Foundation, 2007


  • Canada-U.S. Tax Treaty Issues: Anti-Hybrid Rules, the GAAR, and The U.S. Dual Consolidated Loss Rules, 63:12 Tax Notes Int’l (2011) (co-authored with Peter Repetto).  
  • Stripping Coupons, Filling Gaps: Proposed Amendments to Canadian Withholding Tax on Interest, 22:9 Journal of International Taxation (2011) (co-authored with Andrew S. McGuffin).
  • Notional Expenses of a Permanent Establishment: the OECD Rewrites Article 7, XIV:1 Business Vehicles (2011) (co-authored with David Davachi).
  • Hybrid Foreign Entities, Uncertain Domestic Categories: Treaty Interpretation Beyond Familiar Boundaries, 59:1 Cdn Tax J. 25 (2011).
  • When Is a ‘Nothing’ Something?  Canada’s Approach to Hybrid Entities Under the Canada-U.S. Treaty, 59:4 Tax Notes Int’l (2010).
  • Canada Revenue Agency Considers Interpretation of Antihybrid Rule in Canada-U.S. Tax Treaty, 55:2 Tax Notes Int’l (2009).
  • Canada (chapter), Permanent Establishments, International Bureau of Fiscal Documentation (The Netherlands), April 2009.
  • New Limitations on Imposition of Interest Withholding Tax, Derivatives and Financial Instruments, March/April 2008 (co-authored with Amanda Heale).
  • Permanent Establishments Through Related Corporations Under the OECD Model Treaty, 55:2 Cdn Tax J. 289 (winner of Douglas Sherbaniuk Distinguished Writing Award).