Profile
Gerald Courage’s tax law practice covers the full range of taxation and tax-related matters, with a primary focus on corporate tax. With a tax law background that spans over 30 years, he has provided advice on domestic and international tax issues to a number of significant public and private businesses – based in Canada and abroad – and across a wide range of industries.
Mr. Courage has particular expertise in the tax aspects of mergers and acquisitions, corporate reorganizations, corporate finance and business succession planning. Mr. Courage was elected Chairman of the firm in 2008.
Education
- LL.M., Harvard Law School, 1981
- LL.B., Queen's University, 1977
- B. Comm., University of Toronto, 1974
Professional Achievements
- Best Lawyers in Canada, 2013
Memberships
- Member, Canadian Bar Association
- Member, Canadian Tax Foundation
- Member, International Fiscal Association
- Member, International Bar Association
- Member, Canadian Petroleum Tax Society
- Member, Society of Trust and Estate Practitioners
Faculty Experience
- Lecturer and Chairperson at numerous conferences focused on tax matters, including: Law Society of Upper Canada, Canadian Bar Association (Ontario), Canadian Tax Foundation, Canadian Institute of Chartered Accountants, Federated Press, Canadian Life and Health Association, Canadian Institute and Lexium
- Former lecturer at the University of Toronto on matters relating to taxation and commercial law
Presentations
- Legislation & Budget Update - Federal and Provincial Budgets, Canadian Life and Health Insurance Association, 2008 Tax Officers Annual Meeting, May, 2008
- Utilization of Tax Losses and Debt Restructuring, Federated Press, Ninth Annual Conference on Taxation of Corporate Reorganization, January, 2008.
- The Fifth Protocol: Major Changes to the Canada-US Income Tax Convention, Recent Developments - Business Law in Canada (Spring 2008)
- Tax Issues -- Assets vs. Shares, Miller Thomson LLP, Private M&A "Boot Camp" Seminar, May, 2007.
- Legislation & Budget Update - Federal and Provincial Budgets, Canadian Life and Health Insurance Association, 2007 Tax Officers Annual Meeting, May, 2007.
- Utilization of Tax Losses and Debt Restructuring, Federated Press, Eighth Annual Conference on Taxation of Corporate Reorganization, January, 2007.
- Utilization of Tax Losses and Debt Restructuring, Canadian Tax Foundation, 2006 Ontario Tax Conference, October, 2006.
- Update on Recent Cases, The Canadian Institute of Chartered Accountants, 2006 National Conference on Income Taxes, September, 2006.
- Legislation & Budget Update – Federal and Provincial Budgets, Canadian Life and Health Insurance Association, 2006 Tax Officers Annual Meeting, May, 2006.
- Utilization of Tax Losses, Federated Press, Seventh Annual Conference on Taxation of Corporate Reorganizations, January, 2006.
- Legislation & Budget Update – Federal and Provincial Budgets, Canadian Life and Health Insurance Association, 2005 Tax Officers Annual Meeting, May, 2005.
- Utilization of Tax Losses, Federated Press, Sixth Annual Conference on Taxation of Corporate Reorganizations, January, 2005.
Publications
- Federal Budget Review, 2013
- Legislation & Budget Update - Federal and Provincial Budgets, Canadian Life and Health Insurance Association, 2008 Tax Officers Annual Meeting, 2008
- The Fifth Protocol: Major Changes to the Canada-US Income Tax Convention, Business Law in Canada: Recent Developments, Spring 2008
- Utilization of Tax Losses and Debt Restructuring, Federated Press, Ninth Annual Conference on Taxation of Corporate Reorganization, 2008
- Legislation & Budget Update - Federal and Provincial Budgets, Canadian Life and Health Insurance Association, 2007 Tax Officers Annual Meeting, 2007
- Legislation & Budget Update – Federal and Provincial Budgets, Canadian Life and Health Insurance Association, 2006 Tax Officers Annual Meeting, 2006
- Utilization of Tax Losses, Federated press, Seventh Annual Conference on Taxation of Corporate Reorganizations, 2006
- Manitoba, Tax Notes, Summer 2005
- New Brunswick, Tax Notes, Summer 2005
- Newfoundland, Tax Notes, Summer 2005
- Nova Scotia, Tax Notes, Summer 2005
- Ontario, Tax Notes, Summer 2005
- Prince Edward Island, Tax Notes, Summer 2005
- Saskatchewan, Tax Notes, Summer 2005
- Legislation & Budget Update – Federal and Provincial Budgets, Canadian Life and Health Insurance Association, 2005 Tax Officers Annual Meeting, 2005
- 2004 Federal Budget - Non-Deductibility of Fines and Penalties, Tax Notes, Summer 2004
- February 27, 2004 Technical Bill - Return of Paid-Up Capital by a Public Corporation (Subsection 84(4.1)), Tax Notes, Summer 2004
- Legislation & Budget Update - Federal and Provincial Budgets, Canadian Life and Health Insurance Association, 2004 Tax Officers Annual Meeting, 2004
- Utilization of Tax Losses, Federated press, Seventh Annual Conference on Taxation of Corporate Reorganizations, 2003
- Term Preferred Shares - The Citibank Case, Tax Notes, Summer 2001
- Exchangeable Shares - A Valuable Tool for Cross-Border Takeovers, Tax Notes, Fall 2000
- Weak Currency Loans, Tax Notes, Spring 2000
Key Practice Expertise
Year of Call
- Ontario Bar, 1979