Matias Milet

Matias advises on Canadian tax issues associated with cross-border business ventures and transactions, investment funds and pension funds. His practice has included a broad range of transactions and advice to Canadian and international clients involving tax treaties, the taxation of trusts, corporations and partnerships and the taxation of investments in private equity, infrastructure and real estate by pension funds. Matias has taught international tax at the University of Toronto Faculty of Law and is currently a member of the Editorial Board of the Canadian Tax Journal.

Representative Work

  • Counsel to Manulife Financial Corporation in its $4-billion acquisition of the Canadian-based operations of Standard Life plc. The deal combines Manulife, one of the largest insurance companies in the world, and Standard Life Canada, the country’s fifth-largest insurer
  • Goldman Sachs & Co in cross-border financial instrument transactions
  • Goldman Sachs Asset Management in the establishment of Canadian pooled investment funds
  • Canadian asset manager in a cross-border business restructuring involving delegation of investment management to non-resident sub-advisor
  • Canadian life insurer in resolving complex and large-scale tax filing error
  • Oxford Realty Corporation in its purchase of Brookfield Properties Ltd.’s interest in TD Canada Trust Tower
  • General Electric in internal corporate reorganizations

Latest Insights

  • Osler Update Jul 4, 2024

    Canada’s digital services tax enters into force

    The Digital Services Tax Act (DSTA) entered into force on June 28, 2024, pursuant to an Order in Council (OIC) of that date. The DSTA was enacted by...

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    Canada’s digital services tax enters into force
  • Webinar Apr 18, 2024

    Canadian Tax Law Insights: The 2024 federal budget and its implications for Canadian businesses

    Our National Tax Group lead an in-depth discussion of the 2024 federal budget and what it means for your business.

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    Canadian Tax Law Insights: The 2024 federal budget and its implications for Canadian businesses
  • 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
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Awards and Recognition

  • Best Lawyers in Canada: Recognized in Tax Law
  • Canadian Tax Foundation: Recognized for the Douglas Sherbaniuk Distinguished Writing Award
  • The Canadian Legal Lexpert Directory: Recognized in Corporate Tax

Media Mentions

  • Osler News Apr 19, 2023

    42 Osler lawyers recognized by Lexpert as leaders in Finance and M&A

    Osler is proud to announce 42 of our lawyers have been recognized as leaders in the Lexpert Special Edition: Finance and M&A 2023.

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  • Media Mentions Oct 19, 2022

    Federal Court of Appeal dismisses Charter challenge to CRA-IRS agreement to share banking info – The Lawyer’s Daily

    Osler’s Matias Milet comments in The Lawyer's Daily on the Federal Court of Appeal’s recent dismissal of a claim challenging the...

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  • Media Mentions Dec 17, 2021

    Clock runs out on ETF taxation carve-out – Advisor’s Edge

    A legislative deadline passed December 16 that affects how allocations of capital gains are treated when ETF unitholders make redemptions, leaving...

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Speaking and Writing

Speaking Engagements

speaker 18/4/2024
Canadian Tax Law Insights: The 2024 federal budget and its implications for Canadian businesses
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speaker 20/9/2022
Preparing for Amended Mandatory Disclosure Rules
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speaker 19/11/2017
Canadian Tax Foundation 69th Annual Conference
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speaker 02/11/2017
Osler National Blockchain & Investment Summit
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Published Work

  • “Applying Hybrid Entity Rules in the Canada-U.S. Treaty in a Transfer Pricing Context”, Tax Notes International, April 6, 2020 (co-authored with Roger Smith).
  • Supreme Court of Canada Dismisses Taxpayer’s Appeal in Trust Residency Case, April 13, 2012.
  • IBFD Tax News:  Treaty between Canada and Barbados:  Supreme Court of Canada – Decision on Trust Residence Case, April 16, 2012.
  • 6th Tax-Efficient Finance Structures Course:  Tax Treaty Developments Impacting Cross-Border Financing, May 28, 2012.
  • Presentation:  Character Conversion Transactions and Synthetic Disposition Arrangements
  • Tax Treaty Developments – 2014 NYSBA/OBA Legal Summit, March 28, 2014.
  • Shades of Gray:  Conrad Black’s International Tax Gambit, Tax Notes International, May 12, 2014.
  • 7th Annual U.S.-Latin America Tax Planning Strategies – Base Erosion Profit Sharing, June 5-6, 2014.
  • Civil Unrest:  Collective Investment Vehicles and the OECD, CCH International Tax, December 2014.
  • Canada-U.S. Tax Treaty Issues: Anti-Hybrid Rules, the GAAR, and The U.S. Dual Consolidated Loss Rules, 63:12 Tax Notes Int’l (2011) (co-authored with Peter Repetto).  
  • Stripping Coupons, Filling Gaps: Proposed Amendments to Canadian Withholding Tax on Interest, 22:9 Journal of International Taxation (2011) (co-authored with Andrew S. McGuffin).
  • Notional Expenses of a Permanent Establishment: the OECD Rewrites Article 7, XIV:1 Business Vehicles (2011) (co-authored with David Davachi).
  • Hybrid Foreign Entities, Uncertain Domestic Categories: Treaty Interpretation Beyond Familiar Boundaries, 59:1 Cdn Tax J. 25 (2011).
  • When Is a ‘Nothing’ Something?  Canada’s Approach to Hybrid Entities Under the Canada-U.S. Treaty, 59:4 Tax Notes Int’l (2010).
  • Canada Revenue Agency Considers Interpretation of Antihybrid Rule in Canada-U.S. Tax Treaty, 55:2 Tax Notes Int’l (2009).
  • Canada (chapter), Permanent Establishments, International Bureau of Fiscal Documentation (The Netherlands), April 2009.
  • New Limitations on Imposition of Interest Withholding Tax, Derivatives and Financial Instruments, March/April 2008 (co-authored with Amanda Heale).
  • Permanent Establishments Through Related Corporations Under the OECD Model Treaty, 55:2 Cdn Tax J. 289 (winner of Douglas Sherbaniuk Distinguished Writing Award).



  • McGill University, LL.B (graduated first in class)
  • York University, M.A


  • Spanish
  • French
  • English

Professional Affiliations

  • Law Society of Ontario
  • State Bar of New York
  • Canadian Tax Foundation
  • Canadian Bar Association, Ontario