April 2, 2018
Osler is proud to have earned a Tier 1 ranking from the International Tax Review (ITR) as one of the 2018 Best Transactional Firms in Canada. The inaugural global rankings for the top tax transactional firms — broken up by jurisdiction — were determined by conducting a survey of firms, corporate taxpayers and tax directors of the world’s leading multinational companies. The rankings, announced in a special feature article in the ITR magazine titled “Tax talent: The world’s best transactional firms 2018,” highlight Osler’s expertise in advising on tax transactional matters including M&A, joint ventures and other corporate deals.
The article also reviews the transactional and tax planning trends across the world, including U.S. tax reform. Paul Seraganian, Managing Partner of Osler’s New York Office, has written extensively on U.S. tax reform and talks to ITR about what it means for Canadian businesses.
“Canadian companies looking at acquiring U.S. targets have to evaluate and address the very different landscape for cross-border financing,” Paul tells ITR. “Where tax-advantaged cross-border financing had fuelled superior after-tax returns for Canadian acquirers over U.S. competition, a battery of measures have levelled the playing field of competition within the U.S. marketplace.”
Paul also talks to the ITR about the new anti-hybrid provisions in the overhauled U.S. taxation system, and the coming into effect of the base erosion anti-abuse tax (BEAT).
“These restrictions [on the total debt capacity] are backstopped by the so-called ‘BEAT’ which effectively creates a floor on the amount of U.S. taxable income that can be ‘stripped’ through related party payments,” Paul tells ITR. “These rules do appear to alter after-tax economics in a way that is disadvantageous for Canadian companies looking for M&A opportunities in the US.”
Osler’s Tax Group operates as an integrated unit and in partnership with our clients to develop sophisticated solutions to our clients’ most complex and important tax issues. With close to 60 tax professionals across our offices in Toronto, Montréal, Calgary, Ottawa, Vancouver and New York, we are able to offer our clients expert advice on a broad range of taxation matters including M&A, corporate reorganizations and restructurings, tax controversy and litigation, transfer pricing, Canada/U.S. cross-border tax planning, indirect tax and more.
ITR is subscription resource for tax professionals in industry, government, private practice and research, according to its website. The publication provides subscribers with access to breaking news and analysis, commentary from tax executives, officials and practitioners, as well as comparative discussion of developments in different jurisdictions around the world.
Read more in “Tax talent: The world’s best transactional firms 2018” as part of the March 2018 edition of ITR magazine.