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 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.
Special Edition: MT Federal Budget Review
Miller Thomson’s Tax Group has written a comprehensive review of the 2016 Federal Budget. Our tax lawyers provide insightful review of the Federal Budget’s impact on such issues as International Tax, Business Income Tax, Personal Income Tax, Charities and Not-for-Profit...
Miller Thomson releases comprehensive Federal Budget review March 22, 2016
Tax lawyers Ron Choudhury, Rahul Sharma and Nicole D’Aoust from Miller Thomson’s Toronto office will be in the Federal Budget Lock-up in Ottawa on March 22nd to bring you the latest news on tax measures included in the 2016 Federal...
Miller Thomson publishes Federal Budget Review
Miller Thomson’s Tax Group has written a comprehensive review of the 2015 Federal Budget. Our tax lawyers provide insightful review of the Federal Budget’s impact on such issues as International Tax, Business Income Tax, Personal Income Tax, Charities and Not-for-Profit...
Miller Thomson lawyers make major contribution in global tax publication
In the recently released Thomson Reuters publication “Tax on Transactions Multi-jurisdictional Guide,” six Miller Thomson lawyers from across the country provided their expertise in authoring the Q&A chapter “Tax on corporate transactions in Canada.” Contributors are William Fowlis, Ilan Braude,...
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.
Greg Shannon speaks on tax considerations for real estate
Greg Shannon presents “U.S. and Canada Tax Considerations on Selling U.S. Vacation Real Estate” at the Kelowna Estate Planning Society fall seminar.
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.
Rachel Blumenfeld presents on Estate Administration Tax Act
Rachel Blumenfeld speaks at the 2015 Ontario Tax Conference on “Probate Planning in Light of the Recent Changes to the Estate Administration Tax Act”.
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.
( 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
David Chodikoff quoted in La Presse article on Netflix tax
La Presse, "Netflix devrait payer de la TPS/TVQ, croit le président du CRTC"
(available in French only) Le président du CRTC Jean-Pierre Blais est « surpris » et trouve « étonnant » que Netflix ne perçoive pas de taxe de vente sur ses activités au Canada, alors que les entreprises canadiennes de visionnement en ligne offrant un...
It’s Not Too Late! The New Tax Changes and What You Can Do
Taxes & Wealth Management, Issue 9-3, p. 32-33
Your life insurance policy will be significantly affected by changes coming into effect on January 1, 2017, considerably impacting your estate planning. In 2014, the government introduced changes to the tax rules to help sort out inconsistencies in tax treatments.
The Taxation of Marihuana in Canada
Taxes & Wealth Management, Issue 9-3, p. 18-21
Presently, the future legal regime concerning the future of taxation of marihuana in Canada remains uncertain. Therefore, we are speculating on the nature of the legal framework for marihuana taxation.
Update on Tax Evasion
Taxes & Wealth Management, Issue 9-3, p. 39
Do you remember SCTV? The Great White North? with Bob and Doug McKenzie? The brothers (David Thomas and Rick Moranis, the actors that played the brothers in real life), would commence their “show” by asking: “How’s it goin, eh?” And...
GST and Requirements to Pay: A Case Review of Dan Mason v. Canada
Taxes & Wealth Management, Thomson Reuters, October 2016, Issue 9-3, 22-25
David Chodikoff featured in article on tax evasion
CBA National blog, "Smackdown: Our tax-avoidance heritage meets political pressure"
“Taxes,” said the great American jurist Oliver Wendell Holmes Jr., “are what we pay for civilized society.” Paying what you owe is a basic act of citizenship — but in every national culture with ties to Westminster, there has long...
Solicitor-Client Privilege: It is Just That Important!
Supreme Court of Canada Decisions On Friday, June 3, 2016, the Supreme Court of Canada (the “SCC”) released two important decisions (Canada (Attorney General) v. Chambre des Notaires du Qúebec et Barreau de Qúebec, 2016 SCC 20 (“Chambre des Notaires”)...
The “Delaware – Canco Straddle” for Canadian Tech Start-Ups
Canadian start-ups, including those in the information technology sector (i.e. mobile apps, computer software and other information technologies (“IT”)) may benefit from certain tax and corporate advantages of operating both a Canadian corporation (“CanCo”) and a U.S.-based corporation (often a...
Planning To Sell Goodwill – Tax Implications of the 2016 Federal Budget
Eligible capital property (“ECP”) includes such things as customer lists, franchise rights, licenses, quotas and other intangibles. ECP also includes goodwill, which in general terms is the value of a company beyond the value of its tangible and other specified...
The Panama Papers: More To Come and What It Could Mean For Canadians
Taxes & Wealth Management, Issue 9-2
Associa Canada Holdings Ltd. acquires Harmony Management
Counsel to Associa Canada Holdings Ltd.
True North Commercial REIT closes $32.1 million bought deal offering
Counsel to True North Commercial REIT
BonTerra Resources closes $20 million bought deal financing
Counsel to BonTerra Resources Inc.
Pure Multi-Family REIT LP closes $92 million equity offering
Counsel to the underwriters
Firm Capital American Realty Partners Corp. closes public offering of units
Counsel to Firm Capital American Realty Partners Corp.
Extended Stay Hotels sells its Canadian hotels in $76 million transaction
Counsel to Extended Stay America, Inc.
Just Energy Group commences US$150 million at-the-market MJDS public offering of perpetual preferred shares
Canadian counsel to the agent FBR Capital Markets & Co.
Daseke completes cross-border acquisition of Big Freight Systems
Canadian counsel to Daseke, Inc.
Food packaging manufacturer advised on Canadian aspects of amended and restated multi-currency and multi-jurisdictional syndicated credit arrangements
Counsel to the food packaging manufacturer and its Canadian affiliates
Nesscap Energy completes arrangement with Maxwell Technologies
Counsel to Nesscap Energy Inc.