A significant part of our practice is devoted to sophisticated tax planning and solving complex corporate tax problems. We work with business-owners to address corporate issues from the perspectives of Canadian federal, provincial, and international tax laws.
The depth and diversity of our practice allows us to maintain a leading-edge capability. We advise clients on reorganizations and restructurings involving a variety of ownership vehicles including corporations, partnerships, hybrid entities, as well as domestic and international joint ventures. We frequently provide tax opinions on tax-free reorganizations and obtain advance income tax rulings from the Canada Revenue Agency and Revenu Québec.
We help clients develop tax strategies designed to maximize the benefits of dividend payouts, redemptions and other corporate distributions, to take advantage of incentives such as the lifetime capital gains exemption, and to minimize the impact of punitive anti-avoidance rules. We structure buyouts, spin-offs and other divisive reorganizations and devise plans to maximize the benefits of liquidations and dispositions of separate business segments. We also advise clients in connection with international business migration and expansion.
We work closely with our clients and their corporate, securities, bankruptcy, real estate, environmental, insurance, labor and other advisors to efficiently provide creative and practical tax advice on their transactions.
Financial Products
We advise on the tax implications of all types of financial and derivative products. In dealing with sophisticated products, such as variable prepaid forward contracts, off-market interest-rate swaps, dual-currency debt instruments, equity-index swaps, and contingent principal amount bonds, we have the knowledge and experience to structure the transaction to achieve the desired result relating to the amount, timing, character, and source of income and deduction.
Private Equity and Hedge Funds
Our broad exposure to all areas of taxation allows entities such as private equity and hedge funds to rely upon us for advice in a marketplace that requires immediate decisions. Executives, traders, and chief financial officers at funds we represent call us for prompt advice regarding proposed swaps, trades, and equity investments. Often, we create a tailored structure for a particular investment that takes into account not only the implications specific to the fund itself, but those that might arise for the general partner, the limited partners, and any partners with special tax status (foreign investors, tax-exempt organizations, REITs and others). We have assisted in the structuring of funds, investment management companies, general partners, and vehicles for investment by limited partners. We also help investors evaluate prospectuses of funds for possible investment, assess the tax consequences of both the overall fund strategy and investments and any possible tax considerations specific to an investor’s personal situation.