|
 |
|
|
|
|
Virtually every transaction in which value or money changes hands involves tax issues. The way tax laws are applied can sometimes be a deal-breaker, whether in complex mergers, public/private partnerships or cross-border exchangeable share transactions. FMC’s tax lawyers creatively resolve tax issues, turning them from deal-breakers to deal-makers. We work closely with our colleagues in other practice areas, providing expert tax advice in all corporate and commercial transactions. Our expertise covers all sectors, from entertainment and international transactions, to real estate, mining and natural resources. We advise public and private trusts and corporations, governments at all levels, and high net worth individuals—across Canada and internationally. Our clients’ issues become ours to solve, from long-term tax planning advice to negotiating tax aspects of a deal.
Our tax litigators have extensive experience in resolving all kinds of tax disputes, with all levels of government. They have backgrounds in both tax and litigation—no delegating to litigators who must be brought up to speed on tax. Our group includes Chartered Accountants and lawyers who have worked for the Federal Department of Justice and provincial tax departments. We know how to achieve favourable resolutions quickly, but we will fight in Court when necessary to achieve proper results.
More
|
|
|
|
|
 |
Tax Court Finds that Sales Agents and Home Offices are not "Permanent Establishments" of a U.S. Insurer for Purposes of the Canada-United States Income Tax Convention
|
|
|
|
Successfully argued landmark search and seizure case before the Superior Court of Quebec
|
|
|
|
Successfully represented Prévost Car Inc. in landmark tax treaty case before the Tax Court of Canada
|
|
|
|
Counsel to Jaguar Mining Inc. on $111M offering
|
|
|
|
Counsel to the syndicate of underwriters on $55M offering by Moto Goldmines Limited
|
|
|
|
Counsel to Andean Resources Limited on $40M offering
|
|
|
|
Counsel to Bruce Edmeades Co. and Martin Brower of Canada Co. on $10M acquisition of Bruce Edmeades Co. by Colabor Income Fund
|
|
|
|
Counsel to New Gold Inc. on US$1.6 billion business combination with Metallica Resources Inc. and Peak Gold Ltd.
|
|
|
|
Acted for Developers Diversified Realty Corporation, a publicly traded US-based REIT in connection with a joint venture with Ontario-based property developer, Holborn Property Investments Inc., to acquire and develop a retail/commercial project in the city of Brampton
|
|
|
|
Counsel to the syndicate of agents on $200M IPO by CMP 2008 Resource Limited Partnership
|
|
|
|
Her Majesty the Queen v. Allan McLarty – Acting for Allan McLarty dealing with what is meant by the term ‘expense incurred’ in the context of dealing with acquisitions involving limited recourse financing and whether parties factually deal at arm’s length when a principal has granted an agent authority to carry out an acquisition
|
|
|
|
Société Générale de financement du Québec on $100M acquisition of equity interest in Alliance Films Inc.
|
|
|
|
Counsel to IBI Income Fund on $50M public offering of trust units
|
|
|
|
Acted for UK-based Wood Group on $125M acquisition of IMV Corporation
|
|
|
|
Counsel to Compton Petroleum on $270M sale of conventional oil assets to Birchcliff Energy
|
|
|
|
Acted for Heritage Partners on $24.9M equity investment in Centra Industries Inc.
|
|
|
|
Represented Armtec Infrastructure Income Fund on $120M acquisition of Con-Force, related $60M public offering and of $105M amended/restated credit facility
|
|
|
|
Counsel to the syndicate of underwriters on a $225M bought deal financing completed by NAL Oil & Gas Trust in connection with the acquisition of Seneca Energy Canada by NAL
|
|
|
|
Acted for Meridian Gold in the $3.5 billion takeover bid by Yamana Gold
|
|
|
|
Acted for SouthernEra Diamonds in the $115 million takeover by Mwana
|
|
|
|
Represented Rio Narcea Gold Mines, Ltd. in Lundin Mining Corporation’s $956 million take-over bid for Rio Narcea
|
|
|
|
Counsel to Providence Service Corporation on their entry into the Canadian workforce initiatives market through their acquisition of WCG International Consultants
|
|
|
|
Counsel to CHIP REIT on $1.2B acquisition by bcIMC
|
|
|
|
Advised Pogo Producing Co. of Houston, Texas on their $2 billion (US) sale of their Calgary-based oil and gas company, Northrock Resources Ltd., to Abu Dhabi National Energy Co. (TAQA)
|
|
|
|
Counsel to US Gold Corporation (AMEX, TSX: UXG) in the completion of simultaneous take-over bids for three TSX-V listed gold exploration companies with an aggregate transaction value of US $160 million, 2007
|
|
|
|
Counsel to syndicate of agents on $200M IPO by CMP 2007 Resource Limited Partnership
|
|
|
|
Counsel to Shaw Communications Inc. on $400M Senior Note Offering
|
|
|
|
Counsel to the Canadian syndicate of underwriters in a $523.1M public offering by Enbridge Inc.
|
|
|
|
Advising on all aspects of corporate tax planning, including mergers and acquisitions, cross-border transactions, income trusts and tax-efficient financings
|
|
|
|
Resolving disputes with tax authorities by providing assistance during audits and investigations, preparing effective objections and appeals, and appearing in the Tax Court of Canada, the Federal Court of Appeal and all levels of provincial courts
|
|
|
|
Advising on the federal goods and services tax, customs, international trade, federal and excise duties, provincial sales tax matters, and transfer pricing issues
|
|
|
|
Advising charities and non-profit organizations on Income Tax Act requirements and governance issues
|
|
|
|
Assisting professionals in establishing and selling professional practices in a tax-effective manner
|
|
|
|
Share and debt reorganization of a large resource company involving over $100M in debt
|
|
|
|
|
|
|
|
|
|
|
Recent landmark decisions and implications for your business – Focus on Tax
|
|
|
|
Tax Planning with Partnerships
|
|
|
|
Tax Group's Spring Webinar 2008
|
|
|
|
Tax on Corporate Transactions 2008/09
|
|
|
|
Focus on Tax: Federal Budget 2008
|
|
|
|
Canadian Court Revisits CFC Treaty Provisions
|
|
|
|
The Canada-US Tax Treaty Protocol: Where Have All The Hybrids Gone?, Tax Notes International, v.49, no.3, January 21, 2008, p.271
|
|
|
|
"The Burden of Proof in Tax Cases: Anchor Pointe v. The Queen," Tax Topics, no. 1871, January 17, 2008
|
|
|
|
CRA Reverses Position on Amalgamations
|
|
|
|
Happy New Year! How the CRA has Lengthened the Wait Time for Section 116 Clearance Certificates
|
|
|
|
Canadian Income Trusts
|
|
|
|
"2007 Canadian Tax Foundation Annual Conference CRA Round Table," CCH Canadian Limited, Tax Topics, no. 1867-68, December 20, 2007
|
|
|
|
Focus on Tax - Securities Lending Update
|
|
|
|
"The Rise of Reasonable-But-Mistaken Belief in Section 167? Case comment: Hickerty v. R," Tax Litigation Journal, vol. XV, no. 2, 2007
|
|
|
|
Tax Newsflash – Canadian Tax Law Amendments Affecting Non-Resident Withholding Tax
|
|
|
|
"Anchor Pointe: Confirming the Shifting Onus," Tax Litigation Journal, vol. XV, no. 1 (2007)
|
|
|
|
British Columbia Unlimited Liability Companies (BC ULC)
|
|
|
|
"Subsection 212 (13.2): A Trap for the Unwary?" CCH International Tax Newsletter, No. 36, October 2007
|
|
|
|
"Privilege Claims Under Section 232 of the Income Tax Act" Tax Litigation Journal, Vol. XIV, No. 4 (2007)
|
|
|
|
Focus on Public Policy and Taxation: Canada's Federal Budget 2007
|
|
|
|
The Implications of Withholding Requirements on Non-Residents Providing Services in Canada
|
|
|
|
A New Business Vehicle - Limited Liability Partnerships
|
|
|
|
Claude Desmarais: The Latest Foat in the GAAR Parade
|
|
|
|
Planning and Unstated Tax Policies
|
|
|
|
Full and Partial Shield Limited Liability Partnerships in British Columbia
|
|
|
|
Partnerships - Tax Aspects for Practitioners
|
|
|
|
Many Questions (and a Few Possible Answers) About the Application of Rectification in Tax Law
|
|
|
|
Focus, FMC Vancouver, various articles
|
|
|
|
Focus, FMC Vancouver, various articles
|
|
|
|
Tax Law Strategies for Mining Companies and Their Investors
|
|
|
|
Selected Vendor Issues when Selling a Business: Minimizing the Vendor's Tax
|
|
|
|
Vancouver Taxation Group, Use of Immigration Trust
|
|
|
|
Jehad Haymour, Denny Kwan and Marek Jacina, "Maintaining Privilege in the New Age", (2005) 1 Canadian Petroleum Tax Journal 1.
|
|
|
|
Denny Kwan and Marek Jacina, "Characterizing Convertible Hedges: Round Holes Cannot Fit Into Square Pegs" Case Comment on Hayes v. R., 2005 DTC 5373 (F.C.A.) reversing 2003 DTC 1205 (T.C.C.); CCH Tax Topics, Report #1745, (18 August 2005) 1.
|
|
|
|
|
|
|
|
|