Paul Seraganian - Cross Border Tax Lawyer

Paul Seraganian

New York Managing Partner

Key Contact: U.S. Cross-Border Legal Services

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

Key Contact: Tax

Contact Information

tel: 212.991.2526


New York

Bar Admission

New York, 2001


  • McGill University, LL.B./B.C.L.
  • McMaster University, B.Comm.



Paul’s practice covers a broad cross-section of the firm’s clients, with a particular focus on cross-border mergers and acquisitions, financings and restructurings. He advises on both in-bound and out-bound tax planning considerations, including treaty-based planning, international joint ventures, permanent establishment considerations and the development of innovative cross-border structures. He also regularly advises Canadian pension funds in connection with investments in hedge funds, private equity funds and other private investment vehicles, including designing co-investments and direct investment structures in the United States and globally.  In the domestic context, Paul also has extensive experience advising clients regarding spin-offs, tax-free and taxable reorganizations and acquisitions as well as structuring, operating and unwinding joint venture arrangements. Paul’s representative clients include Cenovus Energy Inc., Encana Corporation, Ontario Teachers’ Pension Plan Board, Iron Ore Company of Canada, Microsoft Corporation, Kinross Gold Corporation and Mitel Networks Corporation.

  • Clio

    Clio in its acquisition of CalendarRules

  • Haivision Systems Inc.

    Haivision Systems Inc. in its acquisition of CineMassive Displays, LLC

  • Acasti Pharma Inc.

    Acasti in its definitive agreement to acquire Grace Therapeutics

  • Wealthsimple

    Wealthsimple in its $750 million financing

  • Caisse de dépôt et placement du Québec

    Caisse de dépôt et placement du Québec and FFL Partners agree to acquire New Look

  • Golder Associates Corporation

    Golder Associates Corporation in its $1.5 billion acquisition by WSP

  • TELUS Corp.

    TELUS Corp. in its $1.2 billion acquisition of Lionbridge AI

  • The Stars Group Inc.

    The Stars Group Inc. in its business combination with Flutter Entertainment plc

  • Encana

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

  • Wave Financial

    Wave Financial in its $537 million proposed acquisition by H&R Block.

  • Neptune Wellness Solutions Inc.

    Neptune Wellness Solutions in its proposed acquisition of SugarLeaf for up to US$150 million

  • Fusion Pharmaceuticals

    Fusion Pharmaceuticals in its US$105 million Series B financing

  • China Molybdenum Co., Ltd.

    China Molybdenum Co., Ltd. in its proposed acquisition of IXM B.V. from NCCL Natural Resources Investment Fund for US$495 million

  • CAE Inc.

    CAE Inc. in its acquisition of Bombardier’s Business Aircraft Training (BAT) business for US$645 million

  • Hopper Inc.

    Hopper Inc. in its Series D Financing Round of US$100 million

  • TELUS Corp.

    The Underwriters in TELUS Corporation's offering of 4.6% notes for US$750 million

  • The Stars Group Inc.

    The Stars Group Inc. in its US$950 million public offering of common shares

  • Healthcare of Ontario Pension Plan (HOOPP)

    HOOPP in its acquisition of a minority stake in Chobani

  • Dominion Voting Systems

    Dominion Voting Systems in its acquisition by its management team and Staple Street Capital

  • South32

    South32 in its $2.1 billion acquisition of Arizona Mining

  • Fullscript

    Fullscript in its merger with Natural Partners

  • Alithya Group Inc.

    Alithya Group Inc., in its going public transaction by way of a business combination with Edgewater Technology, Inc. and completion of a $52.8 million concurrent private placement

  • 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

  • Mitel Networks Corporation

    Mitel Networks Corporation in connection with its acquisition of ShoreTel, Inc. for US$530 million

  • Caisse de dépôt et placement du Québec

    Caisse de dépôt et placement du Québec, in its equity investment in Atlantic Broadband, a subsidiary of Cogeco Communications Inc., in relation to the acquisition of the MetroCast cable systems

    • Canadian Oil Sands Limited in its response to Suncor Energy Inc’s unsolicited takeover bid valued at $6.6 billion
    • Emera Inc. in its proposed US$10.4 billion acquisition of TECO Energy Inc. and $1.9 billion Bought Deal Offering of Convertible Debentures
    • Chemtrade Logistics Income Fund in its $900 million acquisition of General Chemical Corporation
    • DataWind Inc., in connection with its $30 million initial public offering and listing on the Toronto Stock Exchange
    • 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)
    • Ontario Teachers’ Pension Plan in connection with their joint acquisition of Q9 Networks with Bell Canada, Providence Equity Partners and Madison Dearborn Partners for approximately C$1.1 billion in cash
    • Jubilant Organosys Ltd. of India in internal corporate reorganizations
    • Ontario Teachers' Pension Plan in connection with its C$ 2.3 billion joint acquisition (with Hastings Funds Management) of a 50-year lease of the Sydney Desalination Plant from the government of New South Wales, Australia
    • Ontario Teachers’ Pension Plan in the acquisition of Imperial Parking Corporation, one of the largest parking management companies in North America
    • A major French public company in its US$200 million inter-company financing arrangement which was structured as a U.S./Canada cross-border preferred share sale-repurchase (“repo”) transaction
    • A major U.K. public company in its proposed US$5 billion internal restructuring and combination of two US consolidated groups as well as the implementation of a UK-US cross-border tax efficient financing
    • JPMorgan Chase Bank as lender and collateral agent in establishing multiple secured credit facilities to on-shore and off-shore feeder funds, including two syndicated facilities of over US$1 billion each
    • General Electric in internal corporate reorganizations
    • The Bank of Nova Scotia in connection with offering of US$500,000,000 2.375% Senior Notes due 2013 and US$750,000,000 4.375% Senior Notes
    • Sterling Partners and Canada Pension Plan Investment Board in connection with their $324 million acquisition of the assets of Livingston International Income Fund
    • Shell Canada on its $5.6 billion acquisition of Duvernay Oil Corp
    • Fording Canadian Coal Trust in its US$14.1 billion “going private” transaction with Teck Cominco
    • Golden Credit Card Trust’s $400 million Rule 144A offering of receivables-backed senior notes (acted for underwriters)
    • Jubilant Organosys Ltd. of India in its $250 million acquisition of NASDAQ and TSX listed Draxis Health Inc
    • Tristone Capital Global Inc. in the approximately $115 million acquisition of Tristone, a regulated investment bank in Canada, the US and the UK, by Macquarie Group Ltd, an exchangeable share transaction
    • Chartwell Seniors Housing REIT it the public offering of its units in October 2009, December 2009 and October 2010
    • Mitel Networks Corporation in the establishment of credit facilities in an aggregate principal amount of US$430 million in connection with the acquisition of Inter-Tel (Delaware), Incorporated
  • Find More

  • The Tax Club of New York City
  • New York State Bar Association

  • Should Canadian Entrepreneurs Incorporate in the United States?, American Bar Association, May 8, 2020 (with Andre Perey, Marc Kushner and Alix Morse).
  • New York State Bar Association (Tax Section), Report on Section 367(d), October 12, 2010 (contributor).
  • New York State Bar Association (Tax Section), Report on Proposed Regulations Issued Under Sections 367, 1248 and 6038B, January 28, 2009 (contributor).
  • New York State Bar Association (Tax Section), Report on Final Dual Consolidated Loss Regulations, January 23, 2008 (contributor).
  • “Schedule UTP and Evidentiary Privilege in the Tax Law”, Journal of International Taxation (September 2010).