William J. Fowlis, KC, FCPA, FCA, TEP

Associé | Calgary

403.298.2413

Portrait de William J.  Fowlis

( Disponible en anglais seulement )

Aperçu

Bill Fowlis, KC, FCPA, FCA, TEP is a lawyer, a Chartered Professional Accountant/Chartered Accountant, and a Trust and Estate Practitioner (TEP). With this complementary professional background, Bill focuses on taxation, corporate, trust, succession, and estate planning law for privately owned businesses, corporations, family enterprises and high net worth individuals. Bill is considered to be one of the top legal professionals practising in these areas of law in Canada. His practice also covers merger and acquisition transactions with a focus on private corporations and dealing with taxation authorities on contentious matters on behalf of his clients.

Bill is a King’s Counsel, he was appointed Queen’s Counsel in 2014, and awarded a Fellow of the Chartered Accountants (FCA) designation in 2014.

Bill was the national leader in tax law for Miller Thomson from 2008-2015 and the Firm’s national lead for corporate tax from 2015 to 2017. He has been a partner at Miller Thomson since 1988 and was the Calgary office Managing Partner and a member of the Firm’s National Executive Committee from 2000-2006.

Bill is ranked by the Chambers HNW Guide for Private Wealth Law – Canada. He was named Lawyer of the Year for 2015 in the area of tax law for Calgary by The Best Lawyers in Canada list in addition to being listed by Best Lawyers in Canada in the areas of tax law, trusts and estates, corporate law and mergers and acquisitions law. Bill is also listed in the Canadian Lexpert Legal Directory as one of Canada’s leading tax practitioners in the areas of estate and personal tax planning and corporate tax. Bill is recognized in Martindale-Hubbell Directory with an AV Preeminent. He is also rated in Who’s Who Legal in the area of Private Client.

Bill has been an active member of the Society of Trust and Estate Practitioners (STEP) and was Chair of the Calgary branch and a Director of STEP Canada from 2008-2010. Bill served on the Board of the Calgary STEP branch and chaired the STEP Canada Awards Committee for many years. Bill served as an elected representative of STEP Canada on the STEP Worldwide Council from 2017 to 2022 and is also a member of the STEP Governance Committee which he chaired from 2021 to 2023. Bill was a member of the panel of 2015 judges for the STEP Private Client Awards, which celebrate global excellence in private client practice and he has served as a member of the Panel of Experts for these awards. In 2015, Bill received a STEP Founder’s Award in recognition of his outstanding long-term voluntary contributions to STEP.

Bill is recognized as a thought leader as well as an accomplished speaker and writer. He has presented numerous papers on tax topics at conferences, written articles for many publications, and been a frequent lecturer for income tax courses for the Institute of Chartered Accountants of Alberta.

Bill is a member of Conference for Advanced Life Underwriting (CALU) (Associate Member), The International Academy of Estate and Trust Law, Canadian Tax Foundation, Canadian Bar Association and the Entrepreneurial CPA’s of Calgary Society.

Bill completed the FAMILY ENTERPRISE ADVISOR program in 2016 and is a FEA certificant.

Bill is a member of the editorial board of Miller Thomson on Estate Planning, a leading Canadian publication on tax and estate planning.

Réalisations professionnelles et leadership

  • King’s Counsel (appointed Queen’s Counsel in 2014)
  • Awarded an FCA, 2014
  • Certified as a Family Enterprise Advisor, 2017
  • Martindale–Hubbell Directory, AV Preeminent rating
  • Chambers High Net Worth Guide, Private Wealth Law – Canada, 2017 - 2023
  • The Canadian Legal Lexpert Directory, Corporate Tax, 2008 - 2024; Estate & Personal Tax Planning, 2008 - 2024
  • The Best Lawyers in Canada – Trusts and Estates, 2006 - 2023; Tax Law, 2009 - 2023; Corporate Law, 2021 - 2023; Mergers and Acquisitions Law (2022 - 2023)
  • Lawyer of the Year for Calgary, Alberta, The Best Lawyers in Canada – Tax Law, 2015
  • Who’s Who Legal, Canada Guide – National Leader; Canada – Private Client, 2017 - 2023
  • Who’s Who Legal – Global Leader; Private Client, 2018 - 2023
  • Received STEP Founder’s Award, 2015

Leadership éclairé

  • Co-Presenter, “Shared Ownership of Life Insurance,” CALU Fall Conference, November 2022
  • Presenter, “CRA Audit Activity Respecting Trusts – What’s Happening, Preventive Steps and Best Practices,” Entrepreneurial Chartered Professional Accountants of Calgary, November 2021
  • Co-Author, “Intergenerational Transfers of Family Businesses: Bill C-208 and the Path Forward,” published in Taxes and Wealth Management, Fall 2021
  • Co-Presenter, “Estate Planning from Design to Wind-up: Key Tax Issues & Pitfalls,” Canadian Tax Foundation Western Tax Conference, September 2021 with paper published in the Western Tax Conference Report
  • Co-Author, “Update on Bill C-208; New Taxation Rules Impacting Transfers of Family Businesses to the Next Generation,” Wealth Matters, July 2021
  • Co-author, “New Taxation Rules Impacting Transfers of Family Businesses to the Next Generation,” Wealth Matters, June 2021
  • Interviewed for and quoted in Globe and Mail’s Family Business Report, April 2021
  • Presenter, “Trust Audits and Legislative Requirements to Obtain Information about Trusts and Beneficial Owners,” STEP Canada National Webinar, February 2021
  • Author, “Restarting the clock on a trust’s 21 year deemed disposition: The Coronavirus (COVID 19) economy may be the right time,” Wealth Matters, April 2020
  • Moderator, “Taxation of Trusts and Estates Full Day STEP Course,” Society of Trust and Estate Practitioners (Canada), Calgary Branch location, February 2020
  • Presenter, “Current Tax Issues in Trust Planning,” Society of Trust and Estate Practitioners (Canada), Calgary Branch Seminar, February 2019
  • Co-author, “A New Era of Private Corporation Tax Rules,” Tax Notes Parts I to V published between February 5, 2018 and December 20, 2018
  • Co-author, “Planning for the New Passive Income Rules affecting Private Corporations,” Insurance Planning Newsletter (Thomson Reuters), July 2018
  • Presenter, “Shareholder Borrowing Strategies: Tips, Landmines and Pitfalls,” Conference for Advanced Life Underwriting (CALU) National Annual Meeting, May 2018
  • Contributor, “Taxation at Death and Post Mortem Planning Full Day STEP Canada Course,” Society of Trust and Estate Practitioners (Canada), 2018
  • Co-author, “Proposed Amendments to the Taxation of Private Corporations – Where are we now?” Tax Notes, November 27, 2017
  • Presenter, “The July 18, 2017 Finance Proposals – Update, Review of Relevant Examples and Planning Considerations,” Entrepreneurial CPAs of Calgary Society, October 2017
  • Participant, “STEP Canada Special Symposium on Taxation of Private Corporations and Shareholders,” August 2017
  • Presenter, “Estate Planning Considerations for Shareholders in Private Family Enterprises,” Family Enterprise Xchange (FEX) Calgary College, June 2017
  • Panel Member, “Positioning for Family Enterprise Succession’” Family Enterprise Xchange (FEX) Calgary, March 2017
  • Co-author, “Recent Jurisprudence Regarding the Provincial Residency of Trust in Canada,” Wealth Matters, March 18, 2016
  • Co-author, “Command and Control,” STEP Trust Quarterly Review, December 2015
  • Panel member, “Top 10 Sources of Litigation in Will and Estate Planning for Family Business,” Canadian Association of Family Enterprise-Calgary Chapter, November 2015
  • Panel member, “Post-Mortem Planning for Privately Held Corporations: A Re-visitation,” Society of Trust and Estate Practitioners (Canada) National Conference, June 4, 2015
  • Co-presenter, “Trust Update 2015,” Canadian Tax Foundation Prairie Provinces Tax Conference, June 2015, with paper published in the Prairie Provinces Tax Conference Report
  • Panel member, “Post-Mortem Planning for Privately Held Corporations,” Vancouver Branch, Society of Trust and Estate Practitioners, May 2015
  • Panel member, “In Trusts We Trust,” Canadian Association of Family Enterprise Calgary Chapter, February 2015
  • Co-author, “Post Mortem Planning for Private Corporation Shares,” STEP Inside Newsletter, 2015
  • Co-author, “Tax on corporate transactions in Canada,” chapter in Tax on Transactions Multi-jurisdictional Guide, Practical Law (a Thomson Reuters publication), 2015
  • Co-author, “Current Changes to Testamentary Trusts and Continuing Advantages,” Tax Notes, July 31, 2014
  • Panel member, “Post Mortem Planning for Privately Held Corporations,” Society of Trust and Estate Practitioners (Canada) National Conference, June 2014
  • Panel member, “Estate Planning Gone Awry” Conference for Advanced Life Underwriting (CALU) National Annual Meeting, May 2014
  • Presenter, “Tax Issues and Planning Today,” Entrepreneurial Chartered Accountants of Calgary, February 2014
  • Author, “Surplus Stripping: Is the Pipeline Leaking Again?” Tax Notes, August 21, 2013
  • Co-author, “Miller Thomson Federal Budget Review,” 2008-present
  • Instructor, Courses for the Institute of Chartered Accountants of Alberta on Taxation of Family Trusts, Business Succession Planning, Tax Issues for Private Corporate Groups
  • Panel member, “Using a Private Company as a Trustee in Various Canadian Jurisdictions,” Society of Trust and Estate Practitioners (Canada) National Conference, June 2013
  • Presenter, “Current Tax Cases,” Entrepreneurial CA’s of Calgary, February 2013
  • Co-author, “Inter-Provincial Planning–The Alberta Perspective,” STEP Inside newsletter, Society of Trust and Estate Practitioners (Canada), January 2013
  • Co-author, “Beneficial Ownership Test For Tax Treaty Benefit Entitlement,” Tax Notes, November 26, 2012
  • Co-Presenter, “The Final Word(?) on Trust Residence and Thoughts on the Future,” Canadian Tax Foundation Annual Conference, November 2012, which paper was published in the 2012 CTF Annual Conference Report, 2013
  • Co-author, “U.S. Tax and Filing Obligations for Canadians,” Tax Notes, June 13, 2012
  • Presenter, “Case Law Update,” Calgary Branch, Society of Trust and Estate Practitioners, April 2012
  • Author, “2011 Federal Budget—Focus on Anti-Avoidance Rules,” Tax Notes, June 7, 2011
  • Co-chaired Federated Press Tax Planning for the Wealthy Family Course in Calgary, Alberta and presented “Advanced Income Tax Planning for Maximizing Asset Protection,” March 2011
  • Presenter, “Estate Freezes–Planning Considerations, Current Issues and Opportunities,” Canadian Bar Association, South Alberta Wills and Estate subsection, February 2011
  • Presenter, “Shareholder Agreements—Changing Landscape, What to Look For, Common Errors” Calgary Branch, Society of Trust and Estate Practitioners, November 2010
  • Author, “Corporate Trustees: Can a Corporation Other Than a Trust Corporation Act as a Trustee in the Province of Alberta?” Estates, Trusts & Pensions Journal, September 2010
  • Presenter, “Update on Canadian Taxation of Non-Resident Trusts and Foreign Investment Entities,” Canadian Petroleum Tax Society Conference, June 2010
  • Co-author, “International Tax: Corporate Residency – A New Approach to the Application of Central Management and Control,” Tax Notes, March 1, 2010
  • Co-author, “The Use of Estate Refreezing in an Economic Downturn,” Society of Trust and Estate Practitioners International Journal, September 2009
  • Presenter, “Tax Planning in Difficult Economic Times—Implementing or Altering an Estate Freeze and Low-Interest Loan Planning,” National Conference of the Society of Trust and Estate Practitioners (Canada), June 2009
  • Co-presenter, “The Estate Freeze in Difficult Economic Times—the Basics, Opportunities and Challenges,” Canadian Association of Family Enterprise—Calgary CAFÉ College, May 2009
  • Co-presenter, “Canadians Acquiring U.S. Real Property–Cross-Border Tax Considerations,” Canadian Tax Foundation Annual Tax Conference, December 2008, published in the 2008 CTF Annual Conference Report, 2009
  • Author, “The Reversionary Trust Rule Contained in the Income Tax Act (Canada)— Operation of the Rule and Guidance Provided by Recent Jurisprudence,” Wealth Matters, May 2008
  • Co-chair, “Federated Press Tax Planning for the Wealthy Family,” course and presenter, “Advanced Income Tax Planning for Maximizing Asset Protection” and “Owner-Manager Tax Planning,” February 2008
  • Author, “The Reversionary Trust Rule contained in the Income Tax Act (Canada),” Society of Trust and Estate Practitioners International Journal, November/December 2007
  • Presenter, “The 21 Year Deemed Disposition Rule–Operation of the Rule, Planning Strategies and other Issues,” Society of Trust and Estate Practitioners (Alberta) Full Day Seminar, May 2007
  • Presenter “Practitioners Update–Recent Tax Changes,” National Conference of the Society of Trust and Estate Practitioners (Canada), June 2006
  • Presenter, “Tax Products–Issues to Watch for as a Potential Purchaser, Advisor or Promoter,” Society of Trust and Estate Practitioners (Alberta) Full Day Seminar, May 2006
  • Author, “Accountants and the Fiduciary Duty owed to Clients–the Changing Landscape,” Institute of Chartered Accountants of Alberta Spotlight Magazine, Spring 2006
  • Author, “Regulation 105 and Related Cross-Border Withholding Tax Issues,” Tax Notes, Spring 2006
  • Author, “Planning Considerations with respect to Employees Profit Sharing Plans,” Federated Press, Taxation of Executive Compensation and Retirement Journal, Summer 2005
  • Presenter, “Regulation 105 and other Cross Border Withholding Tax Issues,” Canadian Tax Foundation Prairie Provinces Tax Conference, May 2005
  • Presenter, “Legal, Tax and Practical Issues involved with Using a Trust to Carry on Business,” Calgary Branch, Society of Trust and Estate Practitioners, January 2005
  • Author, “Health and Welfare Trusts,” Tax Notes, Spring 2005
  • Author, “Recent Tax, Corporate and Trust Developments,” 2005
  • Author, “Legal Tax And Practical Issues Involved With Using A Trust To Carry On Business,” 2005
  • Author, “New Draft Income Tax Legislation Respecting Non-Competition Covenants and Other Restrictive Covenants,” Tax Notes, Summer 2004
  • Author, “Department of Finance Draft Proposals Regarding The Deductibility of Interest and Other Expenses,” 2004
  • Presenter, “Understanding and Implementing Alberta Advantage Tax and Estate Planning,” Tax and Estate Planning conference, Pacific Business and Law Institute, March 2004
  • Presenter, “Cross Border Planning and Related Tax Issues with respect to Alberta Resident Trusts,” co-written by William Fowlis and Joe Yurkovich, Calgary Branch of the Society of Trust and Estate Practitioners, January 2002
  • Author, “Third Party Civil Penalties—The First Interpretative Views from CCRA,” Institute of Chartered Accountants of Alberta, Monthly Statement Newsletter, March 2001, Law Society of Alberta, Monthly Advisory Newsletter, August 2001
  • Author, “Non-Resident Trusts and Foreign Investment Entities,” Tax Notes, Fall 2000
  • Author, “General Description of the Taxpayer Migration Rules,” Tax Notes, Fall 2000
  • Author, “New Income Splitting: The Kiddie Tax,” Institute of Chartered Accountants of Alberta, Monthly Statement Newsletter, March 2000
  • Author, “Separate Capital Cost Allowance Class Election For Manufacturing and Processing Equipment,” Tax Notes, March 21, 2000
  • Participant in Canada Revenue Agency/Institute of Chartered Accountants of Alberta Roundtable Meetings

Engagement communautaire

  • Rotary Club of Calgary Centennial, 1988-Present
  • Past President, Rotary Club of Calgary Centennial, 1994-1995

Associations professionnelles

  • Member, Law Society of Alberta, 1987
  • Member, Chartered Professional Accountants of Alberta, 1980
  • Member, Society of Trust and Estate Practitioners, 2000
  • Member, The International Academy of Estate and Trust Law
  • Associate Member, Conference for Advanced Life Underwriting (CALU)
  • Member, Canadian Tax Foundation
  • Member, Canadian Bar Association
  • Member, Entrepreneurial CPA’s of Calgary Society

Formation et admission au barreau

  • Alberta, 1987
  • Alberta Bar, 1987
  • B., University of Alberta, 1986
  • In-depth Tax Course, Canadian Institute of Chartered Accountants, 1981
  • CA, Institute of Chartered Accountants of Alberta, 1980
  • Comm., University of Alberta, 1978
  • Completed Family Enterprise Advisor Program, 2016