Taxation

Overview

The Osler Tax Group is consistently recognized as a leading provider of tax law services in Canada. From our offices in Toronto, Montréal, Calgary, Ottawa and New York, 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 are able to offer our clients expert advice on a broad range of taxation 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 taxation advice on many of the most significant transactions undertaken by Canadian corporations, income trusts and other entities within and outside Canada and by foreign corporations and other entities within Canada. We also have extensive experience advising on the taxation aspects of a variety of “mid-market” corporate transactions.
  • General Tax Advisory Services – We provide advice on a broad range of taxation matters of importance to Canadian and foreign corporations, income trusts and other entities, including international tax planning, transfer pricing, corporate finance and capital markets, financial products, private equity, mutual and other investment 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 Litigation/Dispute Resolution – 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 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.
  • Canada/U.S. Cross-Border Tax Planning – From our offices in New York, the Osler Tax Group provides U.S. tax expertise to assist our Canadian clients with operations in the U.S. and our U.S.-based clients with operations in Canada.  Our U.S. tax lawyers in New York work collaboratively with our clients and the tax lawyers in our Canadian offices to provide efficient, expert tax advice in respect of our clients’ Canada/U.S. cross-border operations.
Related Expertise
  • H.I.G. Capital

    H.I.G. Capital in its acquisition of ATX Networks

  • BCE Inc.

    BCE Inc. in its ground breaking pension de-risking strategy

  • Innova Gaming Group Inc.

    Innova Gaming Group Inc. in its Initial Public Offering and Listing on the TSX

  • TPG Capital LP

    TPG in its agreement to form a partnership and acquire the Cirque du Soleil.

  • CanElson Drilling Inc.

    CanElson in its $505 million merger with Trinidad Drilling

  • DAVIDsTEA

    DAVIDsTEA in its initial public offering for aggregate gross proceeds to the company of $64.9 million

  • Bank of Montreal

    Bank of Montreal in a $200 million preferred share issue

  • 2015, International Tax Review: Osler lawyers recognized as leaders in the Women in Tax Leaders Guide
  • 2015, Chambers Global: Taxation (Band 1)
  • International Tax Review, World Tax 2015  (Tier 1)
  • 2015, The Canadian Legal Lexpert Directory: Corporate Tax, "Most Frequently Recommended"
  • 2015, The Lexpert/American Lawyer Guide to the Leading 500 Lawyers in Canada, "Most Frequently Recommended"
  • International Tax Review's World Transfer Pricing 2015
  • The 2015 Lexpert Guide to the Leading US/Canada Cross-border Corporate Lawyers in Canada
  • International Tax Review’s Tax Controversy Leaders 2014
  • 2015,The Legal 500 Canada 2015 (Band 1)
  • 2015,The Best Lawyers in Canada
  • The 2014 Lexpert Guide to the Leading US/Canada Litigation Lawyers in Canada
  • Who's Who Legal: Corporate Tax 2014
  • Who's Who Legal: Canada 2014, with two of our lawyers recognized as “Most Highly Regarded Individuals in Canada” in the area of Corporate Tax
  • Legal Media Group's Guide to the World’s Leading Tax Advisers 2014

  • Canadian Tax Foundation’s 65th Annual Conference

  • Osler Seminar: 2013 Federal Budget – An Overview and Discussion

  • Mining Taxation Strategies March 12 and 13, 2013, Vancouver British Columbia

  • Critical Issues in Corporate Taxation

  • Osler Seminar: Reportable Transaction Rules: Considerations for Financial Intermediaries

  • 17th Taxation of Corporate Reorganizations Conference