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Jennifer Lee

Jennifer Lee

Partner, Taxation

Key Contact: Canada/U.S. Cross-Border Tax Planning

Contact Information

tel: 212.991.2597


New York

Bar Admission

New York, 2011

  • Columbia University, J.D. (James Kent Scholar)
  • Rice University, B.A. (magna cum laude)
English, Mandarin

Jennifer’s practice focuses on the U.S. federal income tax treatment of cross-border and domestic transactions and multinational corporations.  She regularly represents foreign pension funds and governmental entities in connection with investments in hedge funds, private equity funds and other private investment vehicles.  She also regularly advises on U.S. federal income tax aspects of cross-border mergers and acquisitions, financings and restructurings. Jennifer also counsels U.S. non-profit and tax-exempt entities on formation, securing of tax exemption, governance and operation. Jennifer received her J.D. from Columbia Law School, where she served as Head Solicitations Editor on the Columbia Journal of Tax Law.

  • Husky Energy Inc.

    Husky Energy Inc. in its $1.25 billion public offering

  • Fibocom Wireless Inc.

    Fibocom Wireless in its acquisition of Sierra Wireless’ automotive embedded module product line for US$165 million

  • 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

  • Evrim Resources Corp.

    Evrim Resources Corp. in its merger with Renaissance Gold Inc.

  • 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.

  • Encana

    Encana in its reorganization and establishment of corporate domicile in the U.S.

  • Delta-v Capital

    Delta-v Capital in its US$23 million investment in OSF Global Services.

  • Radical Ventures L.P.

    Radical Ventures in the launch of a new $471 million fund.

  • Husky Energy

    Husky Energy in its US$750 million offering of senior unsecured notes

  • iNovia Capital

    iNovia Capital in its $796 million financing for two new venture funds

  • SureWerx

    SureWerx in its acquisition of Jackson Safety® and Wilson Brands From Kimberly-Clark Professional

  • ClearBanc

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

  • Growlabs

    Growlabs in its acquisition by AdRoll Group

  • Husky Energy Inc.

    Husky Energy Inc. in its proposed acquisition of MEG Energy Corp. for $6.4 billion

  • Ensign Energy Services Inc.

    Ensign Energy Services Inc. in its acquisition of Trinidad Drilling Ltd. for $947 million

  • Tilray Inc.

    The Underwriters in connection with the cross-border IPO and NASDAQ listing of Tilray Inc.

  • Healthcare of Ontario Pension Plan (HOOPP)

    HOOPP in its acquisition of a minority stake in Chobani

  • Concentric Agriculture Inc.

    Concentric Agriculture Inc. (previously: Inocucor Technologies Inc.), in its acquisition of ATP Nutrition Inc.

  • Hootsuite

    Hootsuite in its US$50 million credit financing from CIBC Innovation Banking

  • 360insights

    360insights in its acquisition of Through-Channel

  • China Molybdenum Co., Ltd.

    China Molybdenum Co., Ltd. in the sale by Louis Dreyfus Company of its global metals business to NCCL Natural Resources Investment Fund for US$466 million

  • Venzee Inc.

    Venzee Inc. in connection with its going public transaction through the reverse takeover of a TSXV listed issuer renamed Venzee Technologies Inc.

  • Husky Energy Inc.

    Husky Energy Inc. in its acquisition of Superior Refinery for US$435 million

  • Scribble Technologies

    Scribble in its acquisition of ion interactive, inc., an interactive content platform provider

  • Dream Global REIT

    Dream Global REIT in its approximately $903 million transaction relating to a 135 property portfolio in the Netherlands

    • Advised public U.K. multinational group in connection with structuring and financing of multi-billion dollar asset acquisition
    • Chemtrade Logistics Income Fund in its $900 million acquisition of General Chemical Corporation
    • Pure Energies Group Inc., a U.S. and Canada residential solar industry leader in the critical area of web-based customer acquisition, in relation to its sale to NRG Energy, Inc., a company listed on the New York Stock Exchange with a market capitalization of approximately $10 billion
    • Kensington Capital Partners in connection with the fund formation of Kensington Venture Fund, a fund formed pursuant to the Government of Canada’s Venture Capital Action Plan (VCAP)
    • Women in Music, Inc. in connection with its tax exempt status
    • Bank of Montreal in Master Credit Card Trust II’s Rule 144A offerings of credit card receivables-backed notes in October 2012 and July 2013
    • Chartwell Senior Housing REIT in the public offering of its subscription receipts and convertible debentures in Canada and private placement of its subscription receipts in the United States in March 2012
    • Jubilant Organosys Ltd. of India in internal corporate reorganizations
  • Find More

  • “The Changing Landscape of Affiliated Debt Planning: Post-BEPS/Proposed Section 385 Regulations,” Wolters Kluwer (CCH) – Global Tax Weekly, Issue 184 (May 19, 2016) (co-authored)
  • Contributed to New York State Bar Association Tax Section Report on Tax Treaty Consistency Principle, July 2015
  • Contributed to New York State Bar Association Tax Section Report on Notice 2013-78 - Mutual Agreement Procedure, April 2014
  • Security: Tax Issues, Practical Law Company, updated July 2013 (co-authored)
  • US Transfer Pricing: Managing Risks, Practical Law Company, November 2012 (co-authored)