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Indirect Tax

The consequences to a corporation of not having an effective and compliant indirect tax strategy can be far-reaching. Businesses could end up paying more tax than is required. In addition, the possibility of being assessed by tax authorities looms large, with assessments potentially leading to tax disputes and litigation.  

Companies turn to the experts in Osler’s Taxation Group to help them develop an optimal indirect tax strategy that will address these issues and minimize their 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 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, including the invitation-only CPA Canada GST Leaders’ Forum, a group of leading GST/HST experts in Canada. Osler tax practitioners are relied upon to provide

  • Planning and compliance advice — our team provides advice on all aspects of commodity taxation (including GST, HST, QST and provincial sales taxes), customs, import/export controls, excise taxes, fuel taxes, cross-border taxation issues, non-resident taxation issues and taxation issues related to real property development
  • Tax-efficient structuring — our lawyers provide guidance on the tax-efficient structuring of major transactions, corporate reorganizations, tax rulings and interpretation requests, indirect tax management strategies and compliance, due diligence and voluntary disclosures
  • Dispute resolution — this includes audits, objections, appeals and litigation while leveraging the extensive expertise of our lawyers who appear regularly before the Tax Court of Canada and Federal Court of Approval

Key Contacts

Alan Kenigsberg

Partner, Tax, Toronto

Alain Fournier

Partner, Tax, Montréal

Alexander Cobb

Partner, Disputes, Toronto

Roger Smith

Associate, Tax, Toronto


Representative Work

  • Fiera Foods Company

    Fiera Foods in its successful appeal from a Canada Revenue Agency ITC reassessment

  • Hydro One Limited

    Hydro One in its proposed $6.7 billion acquisition of Avista

  • Alphora Research Inc.

    Alphora Research in connection with its sale to Eurofins Scientific

  • The Toronto-Dominion Bank

    The Toronto-Dominion Bank in the sale of its indirect home improvement financing assets to Financeit and Concentra

  • Target Canada Co.

    Target in connection with the wind-down of its Canadian operations under the Companies’ Creditors Arrangement Act

  • Bank of Montreal

    BMO Financial Group in connection with its acquisition of General Electric Capital Corporation’s Transportation Finance Business

  • The Toronto-Dominion Bank in the sale of its indirect home improvement financing assets to Financeit and Concentra
  • Target Canada Co. in connection with the wind-down of its Canadian operations under the Companies’ Creditors Arrangement Act
  • Bank of Montreal in connection with its acquisition of General Electric Capital Corporation’s Transportation Finance Business
  • CIBC World Markets in Osisko Gold Royalties’ $110.7M secondary bought deal offering
  • General Motors Co. in its US$650 million equity investment in Lithium Americas Corp.
  • Royal Bank of Canada in its inaugural Additional Tier 1 offering of $1.75 billion
  • The Toronto-Dominion Bank in the sale of its indirect home improvement financing assets to Financeit and Concentra

Latest Insights

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In the Media

  • Osler News Sep 15, 2023

    National Tax Group recognized with four International Tax Review awards

    Osler announces that our National Tax Group has been recognized with four awards at the 2023 International Tax Review Americas Tax Awards.

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  • Media Mentions Jul 27, 2023

    The immigration and tax law considerations of Canada’s plan to attract digital nomads – Canadian Lawyer

    Dov Begun says that non-residents of Canada can be digital nomads and keep themselves out of the Canadian tax system.

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