Blake Murray

Blake Murray

Partner, Tax

Contact Information

bmurray@osler.com

tel: 416.862.6444

Office

Toronto

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Areas of Expertise

Bar Admission

Ontario, 1975

Education

  • Osgoode Hall Law School, LL.M.
  • Osgoode Hall Law School, LL.B.

Language(s)

English

Blake specializes in taxation with a focus on international taxation and transfer pricing, dispute resolution (including litigation), and tax aspects of corporate finance, reorganizations and merger and acquisitions. From 1989 to 1990, Blake was Senior Counsel to the Standing Committee of the House of Commons on Finance and Economic Affairs with respect to the implementation of the goods and services tax. He has presented papers for, among others, the American Bar Association, the Canadian Bar Association, the Canadian Institute of Chartered Accountants, the Canadian Tax Foundation, the Law Society of Ontario and the Tax Executives Institute.

    • General Motors in its successful out of court restructuring
    • General Electric Capital Canada Inc. adviser in a transfer pricing dispute regarding deductibility of guarantee fees
    • GlaxoSmithKline adviser in a transfer pricing dispute regarding the alleged overpayment for the supply of medication into Canada and an associated licence.
    • Advice with respect to the shut-down and relocation of Canadian operations
    • Advice on restructuring Canadian operations to maintain treaty benefits under the Canada US Tax Convention
    • Various MAP requests regarding, among other things, automotive parts, consumer goods, luxury products and trademark royalties
    • Various APAs regarding, among other things, automotive parts, consumer goods, luxury products and trademark royalties
    • Various transfer pricing disputes regarding, among other things, valuation of interest payable under intercompany loans, valuation of intercompany management services, valuation of foreign subsidiaries, existence of technology and royalty valuation, alleged disposition of customer lists in the course of business restructuring, valuation of buy-in payment for cost sharing arrangement., deemed dividends and transfer pricing penalties

  • Chambers Global: The World’s Leading Lawyers for Business: Recognized in Tax
  • Best Lawyers in Canada: Recognized in Tax Law
  • International Who’s Who: Recognized in International Who’s Who of Corporate Tax Lawyers
  • Euromoney: Recognized in Euromoney Guide to the World’s Leading Transfer Pricing Advisors
  • World Transfer Pricing: Recognized as a Highly Regarded lawyer

  • Canadian Tax Foundation
  • International Bar Association
  • International Fiscal Association

  • Annual lecturer at the Canadian Bar Association Tax Law for Lawyers.
  • Canada’s Transfer Pricing Rules and Contemporaneous Documentation Requirements, Canadian Bar Association Paper, May 29, 2011.
  • Structuring Tax Efficient Supply Chains, The Canadian Institute’s Advanced Forum on Minimizing Double Taxation Through TRANSFER PRICING COMPLIANCE Presentation, February 17, 2011.
  • The Tax Treatment of Intangibles, Canadian Tax Journal (2010), Vol. 58 (SUPP), 201-10.
  • Transfer Pricing: Current Issues and Development in Arbitration Under the Canada-US Tax Convention, 2010 Canadian Tax Foundation Paper.
  • New Protocol to the Canada-US Tax Treaty Signed, Osler Update, September 21, 2007.
  • New Protocol to the Canada-US Tax Treaty Signed, Osler Update, September 21, 2007.
  • Budget Round-Up 2007 Treaty Developments, OBA Taxation Law Section, April 25, 2007.
  • Significant Changes to Proposed Interest Deductibility Restrictions, Osler Update, May 15, 2007.
  • GlaxoSmithKline Settles U.S. Transfer Pricing Dispute for $3.4 Billion: What Lessons Can Be Learned?, Osler Update, January 2007.
  • Source and Residence: New Configuration of Their Principles, IFA Paper, 2005 Buenos Aires Congress.