( Disponible en anglais seulement )
Marc Richardson Arnould specializes in Canadian and international corporate, trust and partnership taxation relevant to the structuring and ongoing operation of private equity and cryptocurrency funds and the financing and continued activities of start-up and emerging entities - with a particular focus on venture capital funds and technology companies, including businesses engaged in distributed ledger technology (DLT - e.g., Blockchain), artificial intelligence (AI) and the internet of things (IOT). Marc also advises on corporate finance transactions, from private placements and traditional initial public offerings (IPO) to crowdfunding campaigns and initial coin/token offerings (ICO/ITO). In addition, Marc’s practice includes both more traditional corporate M&A, acquisitions, holding and exit planning as well as advising investors and issuers on structured financial instruments, including derivatives, hybrid securities, securities loans/lending arrangements, and securitization transactions.
As a member of the Corporate Tax Law practice, Marc works closely with fund managers and investors in connection with the structuring and implementation of private equity and cryptocurrency funds. He also advises individual and corporate clients on the taxation of cryptocurrency transactions – i.e., initial coin/token offerings (ICO/ITO) and the holding, use and disposition (trading) of coins/tokens. In addition, he advises investors and emerging companies in connection with more traditional domestic and international transactions including matters with respect to carrying on business over the Internet, cloud and in the digital environment.
Marc has also advised clients in respect of domestic and international structured corporate finance transactions.
Marc is a regular contributor to both Canadian and international tax publications on a wide range of corporate tax topics. More recently, Marc has written on the taxation of cryptocurrencies (e.g., Bitcoin), crowdfunding activities, initial coin/token offerings, transactions involving cryptocurrencies and tokens, and factors to be considered in structuring and implementing private equity funds. He also presents at seminars, tax conferences (e.g., Le capital de risque, APFF Conference, 2015) and as a speaker at university sponsored events (e.g., Law and the Blockchain: A Crash Course, McGill University, February 2018).
Marc started his legal career at a major international law firm – first in Montreal and then in Toronto – as an associate in the firm’s taxation department where he worked extensively on the structuring of domestic and international investment funds, public and private mergers and acquisitions, and more recently focused on tax matters related to crowdsales and cryptocurrency and token transactions.
Marc Richardson Arnould is a founding member of the Casino Against Cancer – a Montreal fundraising event for the Montreal Cancer Institute – where he headed fundraising and ticket sale initiatives.
- Taxation of Cryptocurrencies & Tokens (Part III) – A Direct, Pre-sale, A Saft & An Ito: An « Immediate Tax Obligation », Taxes & Wealth Management, Vol. 11, No. 4, 9 – 13, November 2018
- Taxation of Cryptocurrencies & Tokens (Part II) – Forking-Up Taxes on Forks?, Taxes & Wealth Management, Vol. 11, No. 3, 4 – 6, October 31, 2018
- Taxation of Cryptocurrencies & Tokens: Simple, Yet Not So Simple, Taxation (Part 1), Taxes & Wealth Management, Vol. 11, No. 2, 6 – 8, October 31, 2018
- Can interest be negative?, Federated Press: Corporate Finance, Vol. XX, No. 4, 2017
- (FCA) Canada v. Green, Canadian Tax Journal, Vol. 65, No.3, 2017
- Private Equity Funds – Selected Canadian Tax Issues, 45 Bloomberg BNA: Tax Management International Journal (TMIJ) 85, February 12, 2016
- Le capital de risque, APFF Annual Conference, October 7, 2015
- Net Management Fee Accepted as Manager’s Consideration for Supply of Services for GST Purposes, Federated Press: Corporate Finance, Vol. XIX, No. 4, 2015
- Case Comment: Bing Zhu v. The Queen – the Exercise of Stock Options and Disposition of Underwater Shares, Federated Press: Taxation of Executive Compensation and Retirement, Vol. XXIV, No. 5, 2015
- Multinational Cash-Pooling Arrangements Face New and Complex Tax Rules, Federated Press: Corporate Finance, Vol. XIX, No. 3, 2015
- No Foreign Exchange Gain on Conversion of Debentures, Federated Press: Corporate Finance, Vol. XIX, No. 3, 2015
- Tax Consequences of Mining and Transacting in Bitcoin, Bloomberg BNA: Tax Management International Journal (TMIJ), Vol. 43, No. 10, October 10, 2014
- Cross-Border Cash-Pooling Arrangements Involving Canadian Subsidiaries: A Technical Minefield, Bloomberg BNA: Tax Management International Journal (TMIJ), 2014
- The Queen v. Lehigh Cement: Federal Court of Appeal Narrows the Interpretation of Paragraph 95(6)(b), CCH International, 2014
- Interpretation of Fixed Dividend Entitlement Ends Questions on Taxable Preferred Share Status, Federated Press: Corporate Finance, Vol. XVIII, No. 4, 2013
- “Crowdfunding” Receipts May Be Business Income, Federated Press: Corporate Finance Vol. XIX, No. 2, 2013
- Paragraphs 110(1)(d) and 7(1)(e): a CRA policy shift?, Federated Press: Taxation of Executive Compensation and Retirement Vol. XXIV, No. 1, 2012
- Copthorne: More on the Concept of Series in Canadian Tax, Federated Press: Corporate Finance Vol. XVI, No. 4, 2010
- Mandatory Arbitration under Article XXVI of the Fifth Protocol to the Canada-U.S. Income Tax Convention: a tax policy analysis, Revista de Direito Trinutario Internacional, Ano. 5, No. 13, 2009
- Speaker, « Applying Laws and Regulations in the Blockchain World », Canadian-Chinese Professional Accountants Association’s « Blockchain: Changing the World » Conference, October 21, 2018
- Law and the Blockchain: A Crash Course, McGill University, February, 2018
- Le capital de risque, APFF Annual Conference, October 7, 2015
- Board Member of the Federated Press Journal, Corporate Finance
- Law Society of Ontario
- Barreau du Quebec
- Canadian Bar Association
- Canadian Tax Foundation (CTF)
- Association de planification fiscale et financière (APFF)
- International Fiscal Association (IFA)
Formation et admission au barreau
- Ontario Bar, 2012
- Quebec Bar, 2012
- CPA Canada In-Depth Tax Course (CICA) – Levels 1, 2 & 3.
- Bachelor of Civil Law & Bachelor of Laws with Distinction, McGill University
- B.A. Honours, Political Studies (Major), French Studies (Minor), Queen’s University