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Matias  Milet

Matias Milet

Partner, Taxation

Contact Information

tel: 416.862.6648



Bar Admission

Ontario, 2005

New York, 2000

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

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.

  • Douglas Sherbaniuk Distinguished Writing Award, Canadian Tax Foundation, 2007

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

  • 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.

  • 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
  • Implications for Private Equity Funds of Canada’s Budget 2014 Proposed Anti-Treaty Shopping, February 13, 2014
  • 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).