Tax Advisory Services

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Obtaining strategic, sophisticated and proactive taxation advice is crucial to an organization’s success – whether it relates to a discrete transaction, day-to-day processes, or overarching business objectives. Osler’s tax law experts apply their specialized knowledge to each client’s situation and ensure that they achieve optimal tax efficiency while managing their tax risk and meeting their compliance obligations.

We provide advice on a broad range of taxation matters of importance to Canadian and foreign corporations, income trusts, pension funds and other entities, including

International tax planning – Canadian and multinational clients engaged in cross-border and international transactions rely on our professionals to provide timely tax planning and liability management advice, and to develop innovative structures that maximize tax efficiencies while taking shifting global realities and foreign tax considerations into account. Osler is a thought-leader in the area of international taxation and our clients benefit from the expertise of our U.S. tax lawyers in the firm’s New York office. In addition, our professionals possess deep knowledge of the OECD’s Base Erosion and Profit Sharing and its impact on tax treaties governing global taxation.

Transfer pricing – Osler has played a leading role in the evolution of the transfer pricing regime in Canada and successfully argued both the leading transfer pricing case before the Supreme Court of Canada and the first case to apply the current transfer pricing approach.

Corporate finance and capital markets – The lawyers in our Taxation Group play a critical role advising on the tax implications of the full range of transaction financing methods, derivatives transactions and capital markets activities, and remain focused on developing the structures that will enable clients to meet their business objectives. For instance, in the area of derivative transactions, we have advised on the use of derivatives as hedging instruments, as a substitute for direct investment and in the context of complex trades and financings by taxable and tax-exempt entities situated in Canada and elsewhere. Our lawyers are recognized in the industry and have a proven track record for delivering innovative tax advice, and for developing novel structures and bringing them to market – see, for example, Osler’s representation of the underwriters in Enbridge’s US$1 billion hybrid note offering and of Emera Inc. in connection with concurrent offerings for $6.2 billion and of The Bank of Nova Scotia in its launch of a new form of Additional Tier 1 Capital for US$1.25 billion.

Private equity and pension funds – Tax structuring is one of the essential legal components of a private equity or pension fund investment strategy. Osler’s tax lawyers work in close collaboration with our private equity and pension fund investment professionals to create structures that comply with Canada’s tax and other regulatory requirements, including pension legislation.

Financial products, including mutual and other investment funds – Clients who are distributing, managing and/or administering investment products regularly turn to Osler’s professionals for timely and strategic tax guidance.

Executive compensation – Osler lawyers have deep experience helping domestic and multinational businesses create innovative and tax-effective compensation and benefits arrangements for their employees and senior executives.

Commodity, sales and use taxation – Commodity and sales taxes can have a significant impact on an organization’s bottom line. Osler’s taxation experts work with businesses to maximize their profitability by minimizing the impact of commodity and sales taxes.

Customs matters – Working in conjunction with our International Trade and Investment Law lawyers, we provide tax guidance on inbound investment into Canada and outbound investment into emerging markets with the overall goal of mitigating risk and achieving client savings.

Industry-specific taxation guidance –  Our Taxation Group leverages the breadth of expertise from across the firm to offer insight and direction geared at particular sectors of the Canadian economy – from banking and insurance, to energy and resource, to technology and e-commerce – and the tax implications associated with operating in specific industries.





  • Greater Toronto Airports Authority

    Greater Toronto Airports Authority in its $400 million offering

  • Enbridge Inc.

    The Underwriters in Enbridge Inc.’s US$1.5 billion public offering

  • TELUS International

    TELUS International in its US$563 million secondary offering

  • Nissan Canada

    The syndicate of agents in Nissan Canada’s $500 million notes offering

  • CGI Inc.

    The Agents in CGI Inc.’s Canadian and U.S. offerings of Notes

  • Chartwell Retirement Residences

    Chartwell Retirement Residences in its $201 million public offering

  • Lightspeed Commerce Inc.

    The Underwriters in Lightspeed Commerce Inc.’s US$823.5 million public offering (including full exercise of the over-allotment option)

  • RBC Capital Markets, LLC

    The syndicate of underwriters in the US$2.50 billion bond offering by the Province of British Columbia

  • RBC Capital Markets

    Syndicate of agents in TELUS Corporation’s $750 million inaugural Sustainability-Linked Bond offering

  • Dream Industrial REIT

    Dream Industrial REIT in its $800 million debenture offering and inaugural green bond issuance

  • Genesis Fertilizers

    Genesis Fertilizers in its urea production and distribution system

  • Laurentian Bank

    Laurentian Bank in its inaugural LRCN offering

  • Clio

    Clio in its US$110 million Series E financing led by T. Rowe Price Associates, Inc. with participation by OMERS Growth Equity

  • goeasy Ltd.

    The Underwriters in goeasy’s $172.5 million subscription receipt offering in connection with its $320 million proposed acquisition of LendCare

  • Dialogue Health Technologies Inc.

    Dialogue in its $100 million IPO

  • Calian Group Ltd

    The underwriters in connection with Calian Group’s $79.7 million bought deal public offering of common shares.

  • Ether Capital

    Ether Capital in its offering of units and concurrent private placement

  • Dye & Durham

    The Underwriters in Dye & Durham’s $500 million offering

  • RBC Capital Markets, LLC

    The syndicate of underwriters in the US$1.75 billion bond offering by the Province of British Columbia

  • MindBeacon

    IPO of MindBeacon Holdings Inc.

  • Haivision Systems Inc.

    Haivision Systems Inc. in its Initial Public Offering

  • AbCellera

    Canadian Counsel to the Underwriters in connection with AbCellera’s IPO and Listing on the NASDAQ

  • Dream Industrial REIT

    Dream Industrial REIT in its $250 million private placement of senior unsecured debentures

  • PyroGenesis Canada Inc.

    PyroGenesis Canada Inc. in its $12 million bought deal and graduation to the TSX

  • Royal Bank of Canada

    Royal Bank of Canada in its Additional Tier 1 offering of Limited Recourse Capital Notes

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