Ron Choudhury has a multi-dimensional tax practice. He is among a handful of tax practitioners whose expertise includes both income tax and sales tax. Ron’s income tax practice focuses primarily on corporate tax, tax planning for high net-worth individuals, and executive compensation issues, while his sales tax practice is geared towards the real estate industry, charities and not-for-profits, and non-residents. Ron is the national Lead for the Sales Tax Specialty Group at Miller Thomson.
Ron advises on corporate tax matters including mergers and acquisitions, divestitures, securitizations, and general corporate reorganizations. He has particular expertise in international inbound and outbound transactions, including treaty issues, the non-resident trust rules, and lending transactions.
Ron’s GST/HST practice includes advice regarding the real estate industry, not-for-profits and charities, exportation, importation and place of supply, GST/HST aspects of corporate transactions, the direct-selling industry, and compliance issues faced by non-residents doing business in Canada.
Ron is a frequent speaker at conferences and he authors multiple articles every year. His articles have been published in noted tax publications, including Global Tax Weekly, Tax Profile, Tax Notes International, Taxation of Executive Compensation and Retirement, and Canadian Tax Highlights. His speaking engagements have included the Annual Conference and the Ontario Tax Conference of the Canadian Tax Foundation, the Annual Conference of the International Bar Association, and conferences organized by Federated Press.
A founding member and past President of the South Asian Bar Association, Ron is active in the general Indo-Canadian community as well as the South Asian legal community. He received the 2016 Cornerstone Award from the South Asian Bar Association—North America, won a scholarship from the International Bar Association, and was a Member of the Year of the Indo-Canada Chamber of Commerce (awarded to the Young Professionals’ Committee chaired by him).
Ron has been featured in his leadership capacities in the National Post and Toronto Star newspapers and interviewed by The Globe & Mail on tax matters.
Professional achievements & leadership
- Winner of Client Choice award in Corporate Tax, 2018
- Recipient, Cornerstone Award, SABA-NA, 2016
- Recipient, International Bar Association Tax Scholarship, 2008
- Founder, South Asian Bar Association of Toronto
- Recipient, Member of the Year, Indo-Canada Chamber of Commerce (Awarded to Committee Chaired by Ron)
- “Canada and Treaty Shopping – From Then to Now”, Tax Notes International
- “Canada’s New Voluntary Disclosure Program”, Global Tax Weekly & Tax Topics
- “2017 Canadian Budget Proposals – A Look to the Future”, Global Tax Weekly & Tax Topics
- “Section 116 Tips & Traps for the Unsuspecting Non-Resident”, Global Tax Weekly
- “Six Tax Havens that Draw Canada’s Wealthy”, Quoted in article on Global and Mail
- “Canada Tempers Foreign Enthusiasm for Real Estate”, Global Tax Weekly
- “US Estate Tax – Partnership Investing in US Realty”, Canadian Tax Highlights
- “Tax Issues on Immigration to Canada”, Global Tax Weekly & Tax Topics
- “Termination of Canadian Residency – Tax Issues & Consequences”, Global Tax Weekly
- “Low-tax Havens Beckon the Wealthiest Retirees” Quoted in article on Global and Mail
- “Select GST/HST Issues for Practitioners,” OBA Tax Institute
- “Final BEPS Report–Canadian Tax Considerations,” Global Tax Weekly & Tax Topics
- “2016 Federal Budget–Promises Kept, Perceived Abuses Addressed,” Global Tax Weekly & Tax Topics & Tax Notes
- “Crowdfunding by Charities,” Miller Thomson Charities Newsletter
- “In Search of an Anti-Treaty Abuse Policy,” Tax Controversy Leaders
- “Employee Secondment–An Overlooked Solution for Non-Resident Employers,” Taxation of Executive Compensation and Retirement
- “Canada Changes Source Deduction Rules for Non-Resident Employees/Employers,” Global Tax Weekly
- “CRA Updates Basic GST/HST Guidelines for Charities,” Miller Thomson Charities Newsletter
- “Immigration into Canada,” Canadian Tax Highlights
- “BEPS and the Digital Economy–Are We There Yet?” Global Tax Weekly
- “New Stock Option Benefit Withholding Provisions–A Critical Look,” Taxation of Executive Compensation and Retirement
- “A Look at the Canada-U.S. FATCA Intergovernmental Agreement,” Tax Notes International
- “Business Vehicles–Corporations,” Tax Profile
- “GST/HST Issues for Non-Residents Carrying on Business in/with Canada,” Tax Profile
- “Select Issues in the Purchase and Sale of a Business” Conference Report,” Ontario Tax Conference
- “New Hong Kong Treaty,” Canadian Tax Highlights
- “Taxation of Partnerships,” Tax Profile
- “Trust Residence: Central Management and Control,” Canadian Tax Highlights
- “Section 116 Notice,” Canadian Tax Highlights
- “Canadian Tax Issues for Non-Resident Franchisors,” Tax Profile
- “No Treaty Exemption for Non-Resident Employee of Foreign Branch of Canadian Employer,” Taxation of Executive Compensation and Retirement
- “LLCs After the Fifth Protocol—Not Quite A Cakewalk,” Tax Notes International
- “HST–A Short-Lived Stay in British Columbia,” Tax Profile
- “FSA Penalties Extended to RRSPs–Impact on Security Awards & Employee Options,” Taxation of Executive Compensation and Retirement
- “Expanded Form T106,” Canadian Tax Highlights
- “RST Bulk Sale Certificates,” Canadian Tax Highlights
- “TCC Decision on Stock Option Surrender Payment Denies Deduction to Grantor,” The Bottom Line
- “Stock Options After Budget 2010–Not As Much Of An Incentive,” Tax Profile
- “Canada’s Greater Scrutiny on Transactions with Non-Arm’s Length Non-Residents,” Tax Notes International
- “New Stock Option Benefit Withholding Provisions–A Critical Look,” Taxation of Executive Compensation and Retirement
- “Provincial New Housing Rebate and HST Transitional Rules for Residential Real Property Announced,” Tax Profile
- “New HST Regime in Ontario–Details and Planning Tips,” Tax Profile
- “Expanded Reporting Requirements under Form T106–Greater Scrutiny on Transactions with Non-Arm’s Length Non-Residents,” Tax Profile
- “The HST: Are you Ready?” Tax Profile
- “Canadian Appeals Court Affirms Late-Filing Penalty,” Tax Notes International
- “Investment Services GST Exempt, for Now,” The Bottom Line
- “Provincial New Housing rebate & HST Transitional Rules for Residential Real Property Announced,” Tax Profile
- “Canada’s Voluntary Disclosure Program,” Tax News International
- “The Scope of Canada’s Stop-Loss Rules,” Tax News International
- “Tax Planning for Immigration to Canada,” Tax News International
- “Lingle v. The Queen–How Subjective is the Habitual Abode Test?” Tax Notes International
- “Ignore GST Considerations At Own Peril in Asset Purchase Transactions,” The Bottom Line
- “Canada 2009–Year in Review,” Tax Notes International
- “Can’t Fill Legal Gaps with Interpretations,” The Bottom Line
- “Tax Consequences of Debt Restructuring and Workouts in Canada,” Tax News International
- “Distress Preferred Shares,” Canadian Tax Highlights
- “Treaty Shopping in Canadian Tax Treaties: A Critical Review of Current Anti-Treaty Shopping Approaches,” International Bar Association
- “GAAR Not Applicable to Deny Terminal Loss in the Absence of Stop-Loss Rule Prohibition–Landrus v. R.,” Tax Profile
- “What is Abusive Tax Planning in the context of the Stop Loss Rules?” The Bottom Line
2007 – 2005
- “Joint Liability for Spousal Tax Debts–Intention and Credibility as Defences to Application of Section 160,” The Estate Planner
- “Flow Through Share Donations–Eating the Cake and Having it Too,” Deadbeat
- “Recent Developments: Shifting the Goalposts on Interest Withholding and Beneficial Ownership,” 2006 Conference Report, Canadian Tax Foundation
- “Non-Resident Issues in Acquisition Transactions,” 2005 Conference Report, Canadian Tax Foundation
- “Repatriation Under the American Jobs Creation Act of 2004–the Canadian CFC’s Perspective,” Taxation Law Bulletin, Ontario Bar Association
- Director and Past President, South Asian Bar Association of Toronto
- Board of Directors, North American South Asian Bar Association
- Canadian Tax Foundation
- International Bar Association
- Ontario Bar Association
- International Fiscal Association
Bar admissions & education
- Ontario Bar, 2002
- LL.M., New York University School of Law, 2003
- LL.B., Osgoode Hall Law School, York University, 2001
- B.A., University of Toronto, 1998
- B.A. (Honours), University of Calcutta, 1996
Ron Choudhury recognized with client service award
We are pleased to announce Ron Choudhury, Partner in our Corporate Tax Group, is among the 2018 winners of the Client Choice Awards in recognition of excellent client service. Client Choice celebrates law firms and partners around the world that...
Miller Thomson to release comprehensive Federal Budget review on March 22
Our in-depth analysis of the Federal Budget will be released later this week. Corporate tax lawyers Ron Choudhury and Rahul Sharma, and Social Impact lawyer Nicole D’Aoust will be at budget lock-up in Ottawa on March 22 to bring you the latest tax measures...
Eleventh edition of Sale of a Business published
The 11th edition of Sale of a Business by Jennifer Babe, a partner in the Banking and Financial Services Group in Miller Thomson’s Toronto office, has now been released. One of Canada’s leading commercial law practitioners, Babe has authored this...
Ron Choudhury honoured by the South Asian Bar Association of North America
Miller Thomson congratulates Ron Choudhury, on receiving the South Asian Bar Association (SABA) Cornerstone Award. Ron was one of four Toronto lawyers honoured at the Association’s Annual National Convention in Houston, Texas, on May 14, 2016. The Cornerstone award recipients...
David Chodikoff and Ron Choudhury speak on tax issues
David Chodikoff co-chairs the Ontario Bar Association’s Institute 2016 program on “Successfully Managing GST/HST and Income Tax Issues in Your Practice”. Ron Choudhury presents on “Select GST/HST Issues for Practitioners”.
Ron Choudhury speaks at tax planning workshop
Ron Choudhury is a speaker at the 9th Tax Planning for the International Client workshop hosted by Federated Press.
Ron Choudhury speaks at compensation and retirement workshop
Ron Choudhury is a speaker at the 13th Taxation of Executive Compensation and Retirement workshop hosted by Federated Press.
Employee Stock Option/Share Ownership Plans Seminar
An ESOP is an important compensation tool for many technology and other owner-managed businesses. Join us as our experts advise on the “do’s and don’ts” of setting up an ESOP. This seminar is designed for business owners, CFO’s, bankers, financial...
Tactical Primer on Mixed-Use Developments
An interactive and informative, fast-paced discussion of hot-button issues in mixed-used developments including: Structuring and risk allocation HST considerations Financing Planning considerations Freehold vs. condominium Leasing Speakers include: Savvas Kotsopoulos, Toronto Anna Balinsky, Toronto Ron Choudhury, Toronto Eric Davis, Kitchener-Waterloo...
Understanding PCs and LLPs: Practical Considerations for Professionals and their Advisors
This seminar is designed for accountants, financial advisors, tax professionals, private business owners, and others who deal with structuring issues. Our seminar focuses on: Tax issues in determining structure Structural alternatives/prohibited structures The extent of limitations on liability Prohibited activities...
Real Estate Joint Ventures Seminar
This seminar on real estate joint ventures covers, dos and don’ts, best practices, competitive intelligence and information sharing. Highlights of this presentation include: Effective and tax efficient structuring Real property and construction Development management, construction management and governance Industry trends...
Draft GST/HST Legislation Impacting Limited Partnerships and General Partners
On September 8, 2017, the Department of Finance (Canada) (“Finance”) introduced draft legislation deeming general partners of “investment limited partnerships” (a newly coined term) to be making a taxable supply when providing management or administrative services (a broadly defined term)....
Ron Choudhury comments on tax considerations for retirement destinations
The Globe and Mail, "Low-tax havens beckon the wealthiest retirees"
Sunny climes have long beckoned retirees who are fed up with freezing Canadian winters. Along with warm temperatures, lower taxes – or no taxes whatsoever – particularly appeal to the wealthy. The controversy over the release of the so-called Panama Papers,...
CRA Updates Basic GST/HST Guidelines for Charities
The Canada Revenue Agency (“CRA”) released an updated version of GST/HST Info Sheet GI-067 (the “Info Sheet”) on May 6, 2015. This version of the Info Sheet, which contains GST/HST guidelines for charities, replaces a previous version issued in June,...
Interaxon Inc. announces US$11.6 million in Series B-1 funding
Counsel to Interaxon Inc.
Addictive Mobility acquired by Pelmorex
Counsel to Addictive Mobility Inc.
Agellan Commercial REIT completes $42.2 million disposition of portion of Parkway Place
Counsel to Agellan Commercial REIT
True North Commercial REIT closes $32.1 million bought deal offering
Counsel to True North Commercial REIT
Creative Planogram Company acquired by SRP Companies
Counsel to Creative Planogram Company
Extended Stay Hotels sells its Canadian hotels in $76 million transaction
Counsel to Extended Stay America, Inc.
Daseke completes cross-border acquisition of Big Freight Systems
Canadian counsel to Daseke, Inc.
Firm Capital Mortgage Investment Corporation closes $23 million bought deal financing
Counsel to Firm Capital Mortgage Investment Corporation
Jabil Circuit acquires Kuatro Technologies
Counsel to Jabil Circuit, Inc.
Rosewood Simcoe acquires Cedarwood Gardens retirement assisted living facility
Counsel to Rosewood Simcoe Inc.