Matias Milet

Matias Milet

Partner, Tax

Contact Information

tel: 416.862.6648



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.

  • BAI Communications

    BAI Communications in the sale of its Canadian business to Rogers Communications

  • H2 Ventures 1 Inc.

    H2 Ventures 1 Inc. in its $5 million initial public offering on the TSX Venture Exchange

  • Goldman Sachs Asset Management

    Goldman Sachs Asset Management in its US$250 million investment in Hydrostor

  • Koch Strategic Platforms

    Koch Strategic Platforms in its US$100 million investment in Standard Lithium

  • Koch Real Estate Investments

    Koch Real Estate Investments in connection with its preferred equity financing of the Canderel-led $5.7 billion acquisition of Cominar REIT

  • Kudu Investment Management

    Kudu Investment Management in its minority stake in Third Eye Capital

  • OPTrust

    OPTrust in USS’ 50% stake in Bruc Energy

  • Ether Capital

    Ether Capital in its offering of units and concurrent private placement

  • Koch Equity Development LLC

    Koch Equity Development LLC in its preferred equity financing of the proposed Cerberus-led acquisition of Dorel Industries

  • 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

  • The Special Committee of Canfor Corp.

    The Special Committee of Canfor in Canfor’s arrangement agreement with Great Pacific Capital

  • BC Partners

    BC Partners in the $5.2 billion recapitalization of GardaWorld

  • Platinum Equity Advisors

    Platinum Equity Advisors in its acquisition of Livingston International

  • Venrock

    Venrock's US$15 million Series B investment in Dapper Labs

  • GFL Environmental Inc.

    Investors led by BC Partners and Ontario Teachers' Pension Plan in the $5.125 billion recapitalization of GFL Environmental Inc.

    • 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
  • Find More

  • 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

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

  • “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).