Carman R. McNary | Fraser Milner Casgrain LLP

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Carman R. McNary Q.C., LL.B., B.A., Partner

Carman concentrates his practices primarily in the area of taxation with emphasis on compliance and dispute resolution with government agencies, and on corporate tax strategies and governance of tax risk. Carman chaired FMC's National Tax Practice group from 2002 to 2012.

Assisting clients with audits and objections to the Canada Revenue Agency, Carman also represents them in appeals to Courts at all levels. He has appeared before the Supreme Court of Canada and extensively before the Tax Court of Canada, the Federal Court Trial Division and Federal Court of Appeal, and all levels of court within Alberta, on matters relating to Income Tax, GST and other commodity taxes. Carman also acts for Canadian and international companies advising on cross-border investment into and from Canada, including cross-border acquisitions, divestitures & reorganizations, transfer pricing and withholding taxes.

Carman is a member of the Board of numerous corporations as well as not for profit organizations, and is a frequent speaker on tax matters. From 2001 to 2006, he was a member of the Faculty as a Sessional Lecturer in Taxation for the Faculty of Law, University of Alberta.

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Assisting clients with audits and objections to the Canada Revenue Agency, Carman also represents them in appeals to Courts at all levels.

Building on over a decade representing Revenue Canada in tax litigation, during which Carman appeared on numerous occasions before all levels of the Courts, Carman represents clients with a view to early and effective resolution of income or commodity tax disputes while defending their interest in paying no more tax than absolutely required. He takes a pro-active approach at all levels of disputes to achieve the most favourable results possible.

Carman provides corporate tax advice and risk management, acting for corporations investing in Canada, and for Canadian corporations investing outside its borders, to ensure efficient and appropriate structures and strategies for tax and commercial issues. He also advises a number of Boards in respect to managing the risks associated with cross-border issues such as transfer pricing, withholdings issues and so on.

Representative Work

Provided tax advice to Canadian clients regarding entry into the Middle East and Africa through a European entity, investment with a U.S. partner into a European operating entity, investments into Central Asia and Australia

Provided tax advice to foreign corporations in respect of inbound investments into Canada

The Queen v. McLarty, 2008 SCC 26.

Successfully represented Mr. McLarty from trial through to a cross appeal to the Supreme Court of Canada

Successfully represented Robert Fraser in a statutory interpretation case in the Federal Court of Appeal (Fraser, The Queen, 2004 DTC 6279)

Successfully represented Echo Bay Mines Ltd. in disputing depreciation on mining equipment (Echo Bay Mines Ltd. v. Canada, 2003 FCA 270)

Publications

Tax Dispute Resolution - Is There a Better Way, CTF 2010 Conference Report (with Paul Lynch and Anne-Marie Levesque)

"When Can 'Incorrect or Incomplete' Be Sufficient to Overcome Deemed Validity?", Tax Topics #2015, October 21, 2010

Lipson: Supreme Court Hands CRA Biggest Ever GAAR Victory in a Cliff-Hanger

Contributor, CCH Canadian Transfer Pricing, 2nd Edition

“Post-Lipson GAAR Cases”, Tax Topics, CCH June 2009

Teaching Roles

Presenter, Canadian Tax Foundation Annual National Conference and Prairie Provinces Conference

Past Instructor, Legal Education Society of Alberta, Bar Admission Course

Past Sessional Lecturer 2001-2006, Taxation, Faculty of Law, University of Alberta

Prior Speaking Engagements

Presenter, Transaction Planning to the Supreme Court of Canada (and Everything in-between): How to Prepare for and Manage Tax Disputes, Alberta Tax Litigation Seminar, Edmonton, November 17, 2011

Presenter, Webinar: Selling Your Business - Tips, Tricks and Traps, Edmonton, October 13, 2011

Co-Presenter, Tax Dispute Resolution - Is There a Better Way?, Canadian Tax Foundation 2010 Annual Conference, November 30, 2010

Panel Chair and Presenter, Canadian Tax Foundation 2008 Annual Conference

Panel Chair, Canadian Tax Foundation 2006 Prairie Provinces Conference

Presenter, “A Review of Recent Cases of Significance – A Case Study on the Development of a Case Law Approach to Tax”, Canadian Tax Foundation 2005 Prairie Provinces Tax Conference

Presenter, “Recent Developments in Tax Practice”, Canadian Tax Foundation 2004 56th National Tax Conference