Tax

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The Osler Tax Group is consistently recognized as a leading provider of tax law services in Canada and is ranked Band 1 by Chambers Canada, one of the leading legal directories in the world. From our offices in Toronto, Montréal, Calgary, Ottawa, Vancouver, our tax lawyers operate as an integrated unit and in partnership with our clients to develop sophisticated solutions to our clients’ most complex and important taxation issues. With close to 60 tax professionals, we offer our clients expert advice on a broad range of tax matters of importance to their business interests. In addition, we are pleased to share with our clients and others the benefit of our extensive experience through our Osler Updates, seminars, webinars and other client tailored programs.

We offer leading expertise and have extensive experience in each of the following areas of corporate tax practice:

  • M&A, Corporate Reorganizations and Restructurings – We work seamlessly as part of a multidisciplinary team that includes corporate, securities, real estate and restructuring lawyers to advise on the taxation aspects of business acquisitions, divestitures, reorganizations and restructurings. We have provided tax advice on many of the most significant transactions undertaken by Canadian corporations, investment funds and other entities within and outside Canada and by foreign corporations and other entities within Canada. We also have extensive experience advising on the tax aspects of a variety of “mid-market” corporate transactions and private client matters.
  • Tax Advisory Services – We provide advice on a broad range of tax matters of importance to Canadian and foreign corporations, investment funds and other entities, including international tax planning, transfer pricing, corporate finance and capital markets, financial products, private equity, mutual funds, pension funds, executive compensation, banking and insurance taxation, commodity, sales and use taxation, customs matters, energy and resource taxation, and technology and e-commerce taxation. We also have extensive experience dealing with officials of the Department of Finance and the Canada Revenue Agency in seeking legislative amendments and advance tax rulings on behalf of our clients.
  • Tax Controversy & Litigation – Our tax litigation lawyers have represented clients in several of the most significant tax litigation matters before the Supreme Court of Canada, the Federal Court of Appeal, the Tax Court of Canada and other courts. The extensive experience of our tax litigators before the courts also provides important perspective and invaluable support for the benefit of clients seeking advice from our M&A and general tax advisory practices. We also have considerable experience in preventing, managing and resolving audit and appeal disputes with the Canada Revenue Agency.
  • Transfer Pricing - We advise on all aspects of transfer pricing including the development of transfer pricing methodologies and the preparation of contemporaneous documentation, the management of transfer pricing audits and the conduct of appeals to the Canadian competent authority and before the Canadian courts.  We were counsel in the first transfer pricing case to consider the scope and application of the current Canadian transfer pricing legislation and we represented the taxpayer in the first transfer pricing case to be heard by the Supreme Court of Canada.
  • Cross-Border Tax Planning – We work closely with leading tax advisers around the world to assist our clients with inbound and outbound cross-border planning advice and dispute prevention and resolution. We work collaboratively with our clients and their foreign tax advisers to provide efficient, expert tax advice in respect of our clients’ cross-border operations.
  • Indirect Tax - We help companies develop an optimal indirect tax strategy to address business issues and minimize liabilities. Our indirect tax practitioners are recognized as some of the nation’s leading advisors and have decades of combined experience advising businesses in the banking, insurance, energy, manufacturing, distribution, retail, and import/export industries on the most tax-efficient ways of structuring their operations. Clients also benefit from the insights and connections gained from our advisors’ participation in various industry groups.
  • Private Client Taxation - Our tax planning lawyers are integral to the successful structuring of our private clients’ assets, estates and associated business succession and estate planning. We focus on developing innovative and tax efficient structures for private clients; providing customized advice for trusts and wills; and drafting and negotiating tax aspects of all types of transaction agreements and other liquidity events. We help our private clients manage their tax risks; comply with complex tax rules affecting individuals, corporations, trusts and estates; anticipate and mitigate scrutiny by tax authorities; and defend tax audits. Our private clients benefit from the formidable expertise of Osler’s tax controversies practice in the event of tax assessments, audits, disputes and litigation.

Osler is a long-time sponsor of the Canadian Tax Foundation (CTF) the International Fiscal Association (IFA), and the Tax Executives Institute (TEI) in support of the professional needs of the in-house tax community and as leading sources of insight on Canadian corporate tax issues.  

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Patrick Marley

Partner and Co-Chair, Tax

Toronto

Mark Brender

Partner, Tax

Montréal

David Jacyk

Partner, Tax

Vancouver

Edward Rowe

Partner and Co-Chair, Tax

Calgary

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  • Chambers Canada: Canada's Leading Lawyers for Business: Recognized in Tax (Band 1)
    • "The depth of the team is unbelievable."
    • "Top operator in the market."
    • "I enjoy working with them - they bring a level of technical expertise that is extremely deep. We get tremendous insight."
    • "Osler is technically strong. They are also commercial and will take a view supported by reasoned and principled judgement in areas with no clear answer. I am very happy with their advice."
  • Chambers Global: The World's Leading Lawyers for Business: Recognized in Tax (Band 1)
    • "They have some superb advisers and produce excellent advisory work."
    • "They have an exceptionally strong team that works together seamlessly - their experience with tax and tax litigation is the best in Canada."
  • The Legal 500: Tax Law (Tier 1)
  • International Tax Review
  • Who’s Who Legal: Osler lawyers recognized in Corporate Tax
  • Best Lawyers Canada: Recognized as "Law Firm of the Year" in the area of Tax Law (Canada), 2022

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