Jack Silverson

Jack specializes in taxation with a focus on the income tax aspects of corporate finance, including developing debt, equity and trust financings, mergers and acquisitions and reorganizations.

He has extensive experience with respect to advising tax exempt entities, real estate investment trusts and income funds. During 1991–1992, Jack was seconded as the Special Advisor to the Director of the Current Amendments and Regulations Division of Revenue Canada and is a former member of the CBA-CICA Joint Committee on Taxation.

Jack is cross appointed to Osler’s Pensions and Benefits Department and is head of the Osler Pension Investment Group.


Representative Work

  • Advising Oxford/OMERS Realty Corporation with respect to the acquisition of 7 Canadian landmark hotels and with respect to the acquisition of indirect interests in a number of English office properties including Mid-City Place in London, the London Stock Exchange’s headquarters, a landmark shopping centre in the Royal Exchange across the street from the Bank of England, an office and retail complex in St. James’s Market in London. (known as the Cheese Grater Building), Green Park Business Park in Reading, and London Wall Place in London
  • Advised OPB on the implications of their participation in a KingSett Capital-led consortium, to purchase Primaris Retail REIT and its leading portfolio of 26 major retail shopping centres and other properties
  • Advised OPB on a debenture offering by a finance trust valued at $500 million – one of the few successful implementations of such an offering by a public sector pension plan in Canada, followed a year later by an additional debenture offering of $250 million
  • Advised OPB in report of Investments in numerous and various domestic and international funds
  • Advised Dundee Realty Corporation with a multi-step reorganization that reorganized the revenue properties of Dundee Realty into Dundee Realty Estate Investment Trust, a publicly traded REIT and subsequent follow on capital markets offerings
  • Advised Fording Inc. with the combination of its metallurgical Coal business with the metallurgical coal businesses of Teck Cominco Ltd. and Sherritt Coal Partnership II to form Fording Canada Coal Trust
  • Advised Issuers or underwriters on the formation of a number of income funds including the Teranet Income Fund, CanWest MediaWorks Income Fund, Pizza Pizza Royalty Income Fund, Second Cup Royalty Income Fund, InnVest REIT and the Home Equity Income Trust
  • Advised CanWest Global Communications in its privatization of CanWest MediaWorks Income Fund

Latest Insights

  • Report Feb 1, 2024

    Guide to Canada’s mandatory disclosure rules

    Introduction Canada's mandatory disclosure rules were significantly expanded in 2023. Three separate regimes comprise the rules: reportable...

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    Guide to Canada’s mandatory disclosure rules
  • Osler Update Nov 10, 2023

    CRA revises and expands its guidance on mandatory disclosure rules

    On November 2, 2023, the Canada Revenue Agency (CRA) revised and expanded its guidance on the Canadian mandatory disclosure rules. The most important...

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    CRA revises and expands its guidance on mandatory disclosure rules
  • Osler Update Nov 3, 2023

    Canadian mandatory disclosure rules update: first list of designated notifiable transactions released

    First list of designated notifiable transactions under the Canadian mandatory disclosure rules published.

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    Canadian mandatory disclosure rules update: first list of designated notifiable transactions released
  • Osler Update Jun 27, 2023

    Bill C-47 introduces significant changes to the Canadian mandatory disclosure rules

    On June 22, 2023, Bill C-47, an Act to implement certain provisions of the budget tabled in Parliament on March 28, 2023, received Royal Assent and...

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    Bill C-47 introduces significant changes to the Canadian mandatory disclosure rules

Awards and Recognition

  • Recognized in Tax Law

    —Best Lawyers in Canada
  • BV Distinguished (4.4 out of 5 Rating)

    —Martindale Hubbell
  • Recognized in Corporate Tax – Canada

    —Who's Who Legal

Media Mentions

  • Media Mentions Dec 13, 2023

    Lawyers exempted from mandatory disclosure regime until Charter challenge decided – Advisor.ca

    An interim injunction exempting legal professionals from CRA’s new mandatory disclosure regime is closely being followed.

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  • Media Mentions Oct 31, 2023

    Legal dilemma – The Canadian Bar Association National Magazine

    New federal mandatory disclosure rules, which substantially expand the number of business transactions that must be reported to the CRA, risk...

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Speaking and Writing

Published Work

Impact of Mandatory Disclosure Rules on the Relationship Between Tax Lawyers and Their Clients, Perspectives on Tax Law & Policy, Canadian Tax Foundation, Volume 4, Number 3, September 2023

Canada’s Reportable Transaction Rules: A Measured Approach to Adviser Reporting. Tax Notes International, Volume 111, July 2023 (co-authored with Matias Milet)

Demystifying the New SIFT Conversion Rules, Canadian Institute January 15, 2009 (co-authored with Lloyd Heine)

Mergers and Acquisitions of REITS, Federated Press, January 2009


Credentials

Education

  • Osgoode Hall Law School, LL.B.

Languages

  • English

Professional Affiliations

  • Canadian Petroleum Tax Society
  • Canadian Tax Foundation
  • Canadian Bar Association, Tax Section