Tax Advisory Services


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.





  • Hydro One Inc.

    Hydro One Inc. in its $1.2 billion offering of Medium Term Notes

  • Telus

    The Underwriters in Telus’ $500 million offering

  • Just Energy Group Inc.

    Osler advises Just Energy Group Inc. in connection with its $1.1 billion recapitalization transaction

  • Chemtrade Logistics Income Fund

    Chemtrade Logistics Income Fund in its $75 million public offering

  • National Bank of Canada

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

  • Husky Energy Inc.

    Husky Energy Inc. in its $1.25 billion public offering

  • Teranet Holdings LP

    The underwriters in Teranet Holdings’ $550 million debt offering

  • Royal Bank of Canada

    Royal Bank of Canada in its inaugural Additional Tier 1 offering of $1.75 billion

  • Workplace Safety and Insurance Board - Pension Plan Conversion

    The Board of Trustees of the WSIB Pension Plan Fund in the conversion of WSIB’s defined benefit, single employer pension plan to a jointly sponsored pension plan

  • Fusion Pharmaceuticals

    Fusion Pharmaceuticals in its $212.5 million IPO

  • Zenabis Global Inc.

    Zenabis Global Inc. in its completed public offering of units

  • Maverix Metals Inc.

    The underwriters in the US$45.54 million cross-border secondary offering of common shares of Maverix Metals Inc. by Pan American Silver Corp.

  • The Bank of Nova Scotia

    The Bank of Nova Scotia in its US$1.25 billion senior notes offering

  • Quicken Loans

    Quicken Loans and Rock Holdings in Edison Financial’s Preferred Round

  • Canadian Pacific Railway’s US$500 million offering

    The Underwriters in Canadian Pacific Railway’s US$500 million offering

  • Canadian Pacific Railway

    The syndicate of agents in Canadian Pacific Railway’s $300 million Canadian offering

  • Hydro One Inc.

    Hydro One Inc. in its $1.1 billion offering of Medium Term Notes

  • Greengate Power Corporation

    Greengate Power Corporation in its agreement with Copenhagen Infrastructure Partners to develop Travers Solar – Canada’s largest operating solar energy project

  • Telus

    The Underwriters in Telus’ $1.5 billion equity raise

  • Verafin

    Verafin in its $515 million venture funding - the largest venture funding deal in Canada’s history

  • RBC Capital Markets

    The syndicate of underwriters in European Residential REIT’s $167 million offering

  • RBC Capital Markets

    RBC Capital Markets in CAPREIT’s $490 million public offering

  • BMO

    BMO in its US$500 million inaugural additional Tier 1 note offering

  • ClearBanc

    ClearBanc in its US$70 million in Seed and Series A financing

  • goeasy Ltd.

    The underwriters in the $46.46 million bought deal offering of goeasy Ltd. common shares by way of a prospectus supplement filed on October 1, 2018

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Canadian enterprises that are invested in the U.S. economy should be keeping a watchful eye on tax reform developments.

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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.

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