Patrick advises on tax issues associated with international tax planning, domestic and cross-border mergers and acquisitions, corporate reorganizations, corporate finance and various other tax matters. He has experience representing clients in various industries including financial services, mining, oil and gas, telecommunications, manufacturing and technology. Patrick appeared before the Canadian Senate Banking Committee in 2008 as a tax expert in respect of proposed foreign investment entity and non-resident trust tax rules. Prior to joining Osler, Patrick worked in the Canadian Department of Finance where he was extensively involved in drafting legislation and formulating tax policy related to foreign affiliates, foreign source income and foreign investments.
Patrick is a contributing editor for CCH’s International Tax, and Tax Management Business Operations in Canada, and is a regular contributor to Tax Management International Journal. Other publications include:
- OECD Discussion Draft Considers Controlled Foreign Corporation Rules, Osler Update, April 2015.
- International Tax Update – OECD/G20 BEPS Project, Tax Executives Institute, March 2015.
- BEPS Symposium: A Canadian Perspective, IFA/CTF, February 2015.
- Cross Border Cash Pooling Arrangements Involving Canadian Subsidiaries: A Technical Minefield, Tax Management International Journal, June 13, 2014
- Impact of BEPS Report and Other Changes on Existing Structures and Proposed Commercial Transactions, IBA/CIOT Conference, February 2014
- Treaty Shopping Review, Canadian Tax Foundation Conference, November 2013
- International Highlights in Canada’s 2013 Budget, Tax Notes International, Volume 70, Number 1, April 1, 2013
- A Review of Foreign Affiliate Reorganization Rules After Recent Amendments, Canadian Tax Foundation Conference, November 2012
- Canada Approves New Foreign Affiliate Dumping Rules, Tax Notes International Vol. 68, Number 6, November 12, 2012
- International Investment Structures for Investment into Latin America, 2012 Fall Meeting Section of International Law, ABA, October 18, 2012
- Foreign Affiliate Proposals, International Fiscal Association, Canadian Branch Seminar, May, 2012
- Adverse Canada-U.S. Tax Treaty Hybrid Entity Rules Coming into Effect January 1, 2010, Osler Update, November 25, 2009
- Limitation on Benefits: Canadian Interpretation, Tax Management International Journal (Vol. 38, No. 10) October 9, 2009
- The Taxation of Mergers and Acquisitions in Canada, IFA - Bulletin for International Taxation August/September 2009 (IBFD)