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, Vancouver 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
  • Emera Inc.

    Emera Inc. in connection with concurrent offerings for $6.2 billion

  • American Capital, Ltd.

    American Capital Ltd. and its Canadian Portfolio Company in its Sale of Service Experts

  • Real Matters Inc.

    The placement agent in a $100 million private placement by Real Matters Inc.

  • China Molybdenum Co., Ltd

    China Molybdenum Co., Ltd in its US$2.65 billion agreement to acquire Freeport-McMoRan’s indirect 56% interest in the Tenke Fungurume copper-cobalt mine

  • Target Canada Co.

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

  • Hydro One Limited

    Hydro One Limited in its $1.97 billion secondary offering of common shares

  • China Molybdenum Co., Ltd

    China Molybdenum Co., Ltd in its agreement to acquire Anglo American PLC’s Brazilian Niobium and Phosphates Businesses for US$1.5 billion

  • Mitel Networks Corporation

    Mitel in its proposed $1.96 billion acquisition of Polycom

  • TransCanada Corporation

    TransCanada in its agreement to acquire Columbia Pipeline Group for US$13 billion

  • Panavision Inc.

    Panavision Canada in connection with its syndicated ABL facilities led by Bank of America

  • International Tax Review: Women in Tax Leaders, 2015, Osler lawyers recognized as leading individuals.
  • Chambers Canada: Canada's Leading Business Lawyers, 2016, Osler ranked in Band 1, Tax.
    • "The quality of service is excellent. The team has a very good relationship with clients and is very prompt."
    • "They've been exceptional and take a pragmatic view of issues."
  • Chambers Canada Awards, 2015, Osler wins Tax Team of the Year.
  • Chambers Global: The World's Leading Business Lawyers, 2003-2015, Osler ranked in Band 1, Tax.
    • "They are a premier tax group."
    • "They bring credibility and objectivity in their advocacy."
  • The Legal 500 Canada, 2015-2016, Osler ranked in Band 1, Tax.
  • International Tax Review: Americas Tax Awards, 2015, Osler wins National Tax Award in Canada.
  • International Tax Review: Americas Tax Awards, 2015, Osler honored for Americas M&A Deal of the Year advising Tim Hortons in its merger with Burger King.
  • International Tax Review, 2015, Osler lawyers recognized leaders in World Tax Guide.
  • International Tax Review, 2015, Osler lawyers recognized as leaders in World Transfer Pricing Guide.
  • International Tax Review, 2015, Osler lawyers recognized as leaders in Women in Tax Leaders Guide.
  • The Canadian Legal Lexpert Directory, 2010-2015, Osler's Corporate Tax Group (Toronto), Most Frequently recommended.
  • The Canadian Legal Lexpert Directory, 2010-2015, Osler's Litigation-Corporate Tax Group (Toronto), Most frequently recommended.
  • The Canadian Legal Lexpert Directory, 2010-2015, Osler's Corporate Tax Group (Calgary), Repeatedly recommended.
  • The Canadian Legal Lexpert Directory, 2012-2015, Osler's Litigation Tax Group (Calgary), Repeatedly recommended.
  • The Canadian Legal Lexpert Directory, 2010-2015, Osler's Corporate Tax Group (Montreal), Consistently recommended.
  • The Lexpert/American Lawyer Guide to the Leading 500 Lawyers in Canada, 2015, Osler lawyers recognized in the area of Corporate Tax.
  • Lexpert Guide to the Leading US/Canada Cross-border Corporate Lawyers in Canada, 2015, Osler lawyers recognized in the area of Corporate Tax.
  • The Best Lawyers in Canada, 2006-2015, Osler lawyers recommended in Tax.
  • International Tax Review, 2014, Osler lawyers recognized in Tax Controversy Leaders Guide.
  • Lexpert Guide to the Leading US/Canada Cross-border Litigation Lawyers in Canada, 2014, Osler lawyers recognized in the area of Tax Litigation.
  • Who’s Who Legal, 2006-2015, Osler lawyers recognized in the area of Corporate Tax.

  • Financing Across Borders — The Disruptive Impact of New U.S. Debt/Equity Rules on Canadian Companies , Offered in-person in our Toronto office or by webinar

  • Taxation

    2016 IFA International Tax Conference , Centre Mont-Royal

  • Employment & Labour

    Calgary Breakfast Seminar Series: Employee Incentives and Budget 2016 , Osler office - Calgary, Alberta

  • 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

International Tax

In an effort to curb multinational tax avoidance and offshore tax evasion in developing countries, the OECD and G20 have created the BEPS project and related action plan.

Learn about the BEPS Action Plan