Miller Thomson’s Corporate Tax Group provides legal advice, representation and cost-effective solutions to clients on a wide array of tax topics. Our lawyers come from a diverse background of education and experience, representing clients in many industry sectors, such as: manufacturing and processing, automotive, real estate, construction, banking and finance, computer equipment and software, oil and gas, the resource service sector, professional services, among others. We are also positioned at the forefront of rapidly growing technological areas, such as cleantech and greentech. Our lawyers are considered thought leaders on tax matters and are frequent speakers at the Canadian Tax Foundation, Canadian Bar Association and Society of Trust and Estate Practitioners conferences as well as author several tax related publications.
Our Corporate Tax expertise encompasses structuring and implementation of mergers and acquisitions (M&A) transactions and financing, reorganizations of public and private companies, investment funds, real estate investment trusts (REITs), income trusts and other entities, transfer pricing, international tax, cross-border taxation, executive compensation issues including stock option and benefit plans. We also regularly advise clients with respect to tax risks and tax filings. Our lawyers have been involved in a broad spectrum of transactions and planning activities including the following:
- Structuring and implementation of mergers, acquisitions and divestitures of Canadian public and private companies and other entities, including by Plan of Arrangement
- Structuring and implementation of going public and private transactions
- Structuring and advising on financing transactions including loan facilities and equity and debt offerings for Canadian and foreign issuers, investors, lenders and borrowers
- Structuring and implementation of take-over bids of Canadian companies and other entities
- Structuring cross-border and international investments in Canada and foreign jurisdictions
- Preparing and advising on tax disclosure in Management Information Circulars, Offering Memorandums, Prospectuses and Annual Information Forms for Canadian and foreign public and private companies, investment funds, REITS and income trusts regarding M&A, financing and reorganization transactions
- Structuring reorganization of public and private corporations, partnerships, investment funds, REITs and income trusts among others
- Structuring sales of businesses using exchangeable shares to maximize available tax deferrals
- Structuring the reorganization of a business to next generation and/or employee ownership
- Advising on flow-through share transactions to finance operations of mining companies
- Advising on the sale and leasing of oil and gas properties
- Advising and establishing structures to effectively use the Canada-US Tax Treaty and other tax treaties
- Advising on transfer pricing approaches, agreements and disputes
- Successfully arranging taxpayer voluntary disclosures
- Advising on rectification regarding tax related transactions
- Representing taxpayers in tax avoidance audits and appeals
- Advising municipal utilities on the tax consequences of privatization and competition
- Advising “Green Companies” on tax efficient structures including the use of federal and provincial tax credits
Miller Thomson recognized in 2018 Canadian Legal Lexpert Directory
In the recently released 2018 edition of the Canadian Legal Lexpert® Directory, 90 Miller Thomson lawyers across 35 areas of law have been recognized for their industry-leading advisory expertise. These rankings are the culmination of an extensive annual peer review process...
Miller Thomson advises winners of top GTA real estate award
On March 22, 2018, NAIOP Greater Toronto announced the winners of the 2017 REX Awards at a gala celebration. NAIOP is the pre-eminent Commercial Real Estate Industry/Development Association in North America. The REX Awards celebrate the achievements of the office, industrial, retail...
Miller Thomson to release Federal Budget Review on February 27
Miller Thomson’s annual Federal Budget Review will be released on February 27. Corporate tax lawyers, Rahul Sharma and Neil Gurmukh, are attending budget lock-up in Ottawa on February 27 to bring you a summary of the 2018 federal budget. In...
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...
Miller Thomson contributes to Taxes & Wealth Management
The October edition of Taxes & Wealth Management has just been released. Published quarterly by Carswell, Thomson Reuters, Taxes & Wealth Management is circulated to over 10,000 email accounts worldwide and is part of the Tax Net Pro service which...
Miller Thomson lawyers recognized in The Best Lawyers in Canada 2017
126 Miller Thomson lawyers from across the country and in numerous areas of law have been recognized for their expertise in the 2017 edition of The Best Lawyers in Canada. This result is up from 122 lawyers ranked last year....
David Chodikoff publishes two prominent texts on tax law
Tax Litigation, 2nd ed. (Sweet & Maxwell) is a complete resource guide to tax litigation in both the civil and criminal context for thirty countries around the globe. David was General Editor and recruited the law firms from the thirty jurisdictions...
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 receives 2016 IAE award for Tax Litigation (Canada)
The International Alliance Network is a global alliance of legal, financial and consulting firms from over 140 jurisdictions. All nominees are researched, then shortlisted and winners are determined by the decision of an independent panel.
Cathie Brayley speaks at CBA Tax Law for Lawyers conference
Cathie Brayley is a speaker at the Canadian Bar Association’s Tax Law for Lawyers conference, presenting on the topic “Purchase and Sale of a Business/Asset Sales”. Cathie was part of the original planning committee for this conference, now in its...
Bryant Frydberg speaks on Succession Planning for Businesses
Bryant Frydberg speaks at the Calgary Chamber of Commerce CEO Roundtable event. He will speak on the subject of succession planning for businesses and what are the best options, tax implications and legal obligations they face.
David Chodikoff speaks on Essential Tax Updates
David Chodikoff is presenting on “Essential Tax Updates: Dividend Traps, Small Business Deductions, Rectification and Privilege” at the 2017 OBA Institute.
Rahul Sharma and Amanda Stacey speak at OBA Tax Update program
Rahul Sharma co-presents a Tax Update presentation to the Tax and Estates Section of the OBA. Amanda Stacey is moderating the panel.
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”.
Rahul Sharma speaks on tax losses
Rahul Sharma presents “Use of Tax Losses” at the 20th Taxation of Corporate Reorganization.
Martin Rochwerg speaks at tax planning workshop
Martin Rochwerg is course leader for the 17th Tax Planning for the Wealthy Family 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.
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.
William Fowlis of our Calgary office will be presenting as part of a panel presentation on “Post Mortem Planning for Privately Held Corporations – An Update” at the Society of Trust and Estate Practitioners (Canada) National Conference on June 19, 2015.
( Available in French only )
Vérifications fiscales… Évitez la catastrophe!
Tout entrepreneur doit savoir comment agir face à une demande de vérification fiscale de Revenu Québec ou de l’Agence du revenu du Canada. Lors de ce « Lunch & Learn » présenté à La Gare|Espace collaboratif, vous obtiendrez des conseils pratiques pour vous y...
Recent Tax Developments 2015 – Saskatoon
Crystal Taylor, Bryant Frydberg, Graham Purse and Lesley Akst speak at a seminar hosted by Miller Thomson on Recent Tax Developments.
Recent Tax Developments 2015 – Regina
Crystal Taylor, Bryant Frydberg, Graham Purse and Lesley Akst speak at a seminar hosted by Miller Thomson on Recent Tax Developments.
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...
Tax Update Seminar
Miller Thomson presents a complimentary tax seminar. This seminar is designed for accountants, financial advisors, tax professionals, private business owners, and others who deal with tax related issues. Our seminar focuses on: New Tax Rules affecting Trusts, Estates and Charitable...
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...
Tax Update 2015 – Calgary
Date: Wednesday, April 1, 2015 Time: 7:00 a.m. – 7:25 a.m. Breakfast and Registration, 7:25 a.m. – 9:00 a.m. Presentations Location: Calgary Petroleum Club, Devonian Room, 319 – 5 Ave S.W., Calgary, Alberta
Recent Tax Developments 2014 – Regina
A New Era of Private Corporation Tax Rules – Part III
Just over a year ago, Budget 2017 announced that the Government was reviewing the taxation of private corporations. A consultation paper and draft legislation were released on July 18, 2017, which included amendments to section 120.4 of the Income Tax...
New Opportunities for Investors in the Saskatchewan Technology and Agricultural Sectors Following the Release of Saskatchewan’s 2018-2019 Provincial Budget
On April 10, 2018, Saskatchewan’s Minister of Finance, Donna Harpauer, presented Saskatchewan’s provincial budget for 2018-2019. The budget announces two new incentives for investments in the technology and agricultural sectors: 1. The Saskatchewan Technology Start-up Incentive This two-year pilot program...
CBSA’s 2018 Trade Compliance Priorities: Which Goods Are On Their Radar?
Recently, the Canada Border Services Agency (the “CBSA”) released its Trade Compliance Verification priorities for 2018. The CBSA manages trade compliance with the (i) Tariff Classification, (ii) Customs Valuation, and (iii) Origin programs. This is done by way of random...
Secured Creditor’s Priority Over Unremitted GST/HST: SCC Grants Callidus Capital Corporation Leave to Appeal
On March 22, 2018, the Supreme Court of Canada granted Callidus Capital Corporation (the “Secured Creditor”) leave to appeal the Federal Court of Appeal decision that interpreted subsection 222(3) of the Excise Tax Act (Canada) (the “ETA”) as giving the...
A Cautionary Tale Regarding the GST/HST New Housing Rebate
As an incentive to a prospective buyer, a builder may offer to provide a credit to decrease the purchase price of a newly-constructed or substantially renovated detached house, duplex, or condominium unit (collectively referred to as a “Home“) in exchange...
Budget 2018: Developments Affecting Private Companies
In this edition: Passive Income Proposals for Private Corporations Increased Reporting Requirements for Trusts Passive Income Proposals for Private Corporations Budget 2018 contains two new measures to deter the accumulation of passive assets within private corporations. These changes are...
$1.4 million award against CRA for malicious, high-handed, and reprehensible conduct – Samaroo v. Canada Revenue Agency, 2018 BCSC 324
Unfortunately, we see the odd bad apple in our civil and criminal dispute resolution practice involving the Canada Revenue Agency (CRA). We try to resolve these matters prior to pursuing the extreme route involving litigation. As one can see from...
Budget 2018: Sales and Excise Tax Proposals
The 2018 Federal Budget (“Budget 2018”) contains a number of excise and sales tax (GST/HST) proposals and amendments that may be relevant to registrants and practitioners. Each of the proposals below deals with issues that may require significant planning or...
2018 Miller Thomson Federal Budget Review
With today’s tabling of the 2018 Federal Budget (the “Budget”), the federal government followed through on its previously expressed commitments to reform the taxation of passive income earned by certain private Canadian corporations. It has also continued to “tighten” the...
A New Era of Private Corporation Tax Rules – Part II
The announcement in Budget 2017 that the Government was reviewing tax reduction strategies using private corporations created uncertainty and much speculation. On July 18, 2017, draft legislation (the “July Proposals“) was released, which proposed to amend many sections of the...
FDF Brandz led by Ricky’s Group of Family Style Restaurants acquires Famoso Neapolitan Pizzeria chain
Counsel to FDF Restaurant Brandz, a leading privately held restaurant franchising company, in its acquisition of the Famoso Neapolitan Pizzeria chain
GP Strategies acquires IC Axon
Canadian counsel to GP Strategies
Green Organic Dutchman completes $132 million IPO
Counsel to the syndicate of agents co-led by Canaccord Genuity Corp. and PI Financial Corp.
Chartwell acquires four Edmonton retirement communities in $297.9 million transaction
Counsel to one of the vendors
Mountain Province Diamonds completes business combination with Kennady Diamonds
Counsel to the special committee of Mountain Province Diamonds
Crown Holdings completes acquisition of Signode Industrial Group Holdings
Canadian counsel to Crown Holdings, Inc.
Sunlife and Bentall Kennedy in joint venture to develop premier rental location in Toronto’s Parkdale neigbourhood
Counsel to Sun Life Investment Management and Bentall Kennedy
True North Commercial REIT completes $40.3 million offering of trust units
Counsel to True North Commercial REIT
Safety Express acquires Norclean
Counsel to Norclean and its shareholders
CanLII acquires Lexum
Counsel to CanLII