Michael Friedman 

Co-Chair, Tax

Michael Friedman

Toronto
Brookfield Place, Suite 4400
181 Bay Street
Toronto, Ontario M5J 2T3

t: 416.865.7914
e: michael.friedman@mcmillan.ca

overview

Michael is a tax partner and Co-Chair of the firm's Tax Group. Michael advises clients on a diverse range of domestic and international taxation matters and has specialized expertise in structuring domestic and multi-national commercial acquisitions, divestitures, reorganizations and business combinations. Michael counsels clients on the tax elements of all major aspects of ongoing business operations, including employee compensation and stock option planning, tax and reporting compliance, transfer pricing, and voluntary disclosures.

Michael regularly counsels investment funds and asset managers on the establishment and administration of tax-efficient investment vehicles. Michael has been an active member of the McMillan Tax team that has stood at the forefront of the development of tax-efficient investment fund structures, including Master-Feeder funds, switch funds, and specialized return funds. Michael has assisted with the formation of a large number of institutional and specialized structured products catering to a wide range of domestic and offshore investors, specialized portfolios, and investment techniques, and advises a variety of domestic investment managers retained by international investment funds.

Michael regularly advises clients on the taxation and efficient structuring of hedging transactions, derivative instruments, securities lending arrangements, and repo transactions.

Michael has broad experience, and has enjoyed great success, representing clients in resolving tax disputes with both the Canada Revenue Agency and the provincial revenue authorities. Michael has appeared before both the Tax Court of Canada and the Federal Court of Appeal.

Representative Matters

  • Acted for Public Mobile Inc. in connection with the acquisition of the telecommunication company by Thomvest Seed Capital Inc.
  • Acted for Detour Gold Corporation in its approximately $84 million acquisition of Trade Winds Ventures Inc. by way of a plan of arrangement
  • Acted for the underwriting syndicate in a bought deal equity offering for Perseus Mining Limited with gross proceeds of $93.4 million
  • Acted for Goldstone Resources Inc. in the approximate $104 million purchase thereof by Premier Gold Mines Limited
  • Acted for the dealer managers in connection with a $1.18 billion rights offering by Ivanhoe Mines Ltd.

Presentations

The Characteristics and Uses of Limited Partnerships
Associated Affiliated and Related: The Implications
FATCA Workshop for Portfolio Managers
The Future of Business Taxation in Canada: An Insider's Perspective
Crossing the 49th Parallel: Best Practices in Canada-US Corporate Transactions
Emerging Managers Seminar Series: Doing Business Offshore
Transfer Pricing Documentation Requirements
Key Tax Issues for Corporate Counsel: Identifying and Managing Tax Risk
Navigating the Minefield: An Advisor's Guide to Penalty Taxes and Other Tax Pitfalls
Taxation of Franchises: From Home and Abroad
Transfer Pricing Documentation Requirements
Securing & Sustaining 'Mutual Fund Trust' Status - Tips & Traps
The Characteristics and Uses of Limited Partnerships
The Characteristics and Uses of Limited Partnerships
Challenges when Structuring Cross-Border Transactions and Political Solutions
Income Trusts Revisited: The Canadian Income Tax Implications of the Proposed "SIFT" Rules

Publications

Budget 2016: Expanding Tax Support For Clean Energy
Budget 2016: Labour-Sponsored Venture Capital Corporations Tax Credit Re-Introduced
Budget 2016: Debt Parking Rules Expanded to Address Foreign Currency Denominated Debts
Budget 2016: Taxation of Emissions Trading Activities Clarified
Budget 2016: Eligible Capital Property Rules Revamped
Budget 2016: New Rules Governing the Taxation of "Switch Fund" Shares
Number of Voluntary Disclosures Continues to Increase
Tax Withholding Obligations of Non-Resident Employers: Further Exemption Details Released
Are Changes to the Flow-Through Share Regime Around the Corner?
New Government's First Round of Tax Changes Introduced in Parliament
Significant Tax Changes on the Horizon
Budget 2015: Penalties for Tax Reporting Failures Modified
Budget 2014: Revisions to the Tax on Split Income (the "Kiddie Tax")
Budget 2014: Thin Cap and Withholding Tax Rules Get Tougher
Hong Kong - Canada Tax Treaty in Force
Canada: Audit Guide
Government of Canada announces new support for Canadian venture capital funds
Ontario budget 2013: employer health tax changes
Budget 2013: broadening the application of Canada's thin-capitalization rules
Budget 2013: international tax compliance
Budget 2013: further restrictions on loss trading
Budget 2013: deconstructing derivatives – capturing "character conversion transactions"
Budget 2013: proposed consultation on changes to the income tax rate applicable to trusts and estates
Budget 2013: synthetic dispositions
Budget 2013: changes to personal income tax rules
Budget 2013: enhanced SR&ED enforcement measures announced
Budget 2013: capital cost allowance enhancements unveiled
Budget 2013: changes to the taxation of resource industries
finance proposes amendments to the "prohibited investment" rules
Canada Unveils Significant Amendments to Thin Cap Regime
Budget 2012: new "foreign affiliate dumping" measures introduced
Budget 2012: expansion of "prohibited investment" and "advantage" rules to retirement compensation arrangements ("RCAs")
Budget 2012: transfer pricing amendments proposed
Budget 2012: government moves to further expand the tax shelter rules
Budget 2012: tightening of the "thin capitalization" rules unveiled
Budget 2012: changes to the taxation of resource industries
Budget 2012: flexibility for eligible dividend designations introduced
Ontario budget 2012: an indication of things to come
The New RRSP/RRIF Anti-Avoidence Regime
proposed legislative amendments shore up safe harbour for non-resident investment funds
further changes to new RRSP/RRIF anti-avoidance rules introduced
A Matter of Fairness: Cancellation of Interest and Penalties under the Canadian Taxpayer Relief Provisions
Securing & Sustaining "Mutual Fund Trust" Status – Tips & Traps - Part 2
'New' Canadian treaty eligibility forms – Implication for cross border derivatives agreements
CRA Releases "New" Treaty Eligibility Forms – Are there New Compliance Obligations to be Met Before Applying a Treaty Reduced Rate of Withholding Tax?
Employee Stock Options: New tax withholding requirements
Canada Revenue Agency Releases New Treaty Eligibility Forms
An Overview of the Canada Revenue Agency's Voluntary Disclosures Program
budget 2011: extension of the super flow-through share program
budget 2011: partnership deferral benefits eliminated
budget 2011: accelerated capital cost allowance for the M&P and clean energy sectors
budget 2011: proposed changes target abuse of RRSPs and RRIFs
Coming Clean to the CRA: An Introduction to the Federal Voluntary Disclosures Program
The Federal Court of Appeal - Ambiguity Resolved: Non-Resident Corporations that late-file Nil Returns Subject to Penalties
Canada's New Tax Return Filing Requirements for Partnerships
Transfer Pricing Documentation Requirements
Are you Eligible to Make a Valid Voluntary Disclosure?
U.S. Tax-Exempts and Article XXI of the Canada-U.S. Treaty: Claiming an Exemption from Canadian Withholding Tax
Ambiguity resolved: Canadian Federal Court of Appeal upholds late-filing penalties for non-residents
Canada chapter in: Getting the Deal Through - Mining 2010
Change in Canadian tax rules make it easier to invest in Canada
CRA to Fund Compliance-Related Education and Training Initiatives
Canadian Court Upholds Late-Filing Penalties for Nonresident Corporations
The P Factor: The Puzzling Predicament Posed by Problematic Penalty Provisions – Are Non-Resident Corporations That Late-File Nil Returns Subject to Penalties
Canada chapter in: Getting the Deal Through - Mining 2009
Canadian Late Filing Penalty Successfully Challenged
Federal Court of Appeal upholds favourable judgment on the tax treatment of cross-border investments
Canada and the U.S. Ratify Significant Tax Treaty Changes
Transfer Pricing Documentation Requirements in Canada
Canada chapter in Getting the Deal Through – Mining 2008
Canada reduces tax reporting for non-residents
Transfer Pricing Documentation Guide
Budget 2008: Budget promises to lessen tax reporting burden on foreign-based private equity funds investing in Canada
Canadian Government to Lessen Tax Reporting Burden on Non-Residents
Budget 2008: Extension of the Super Flow-Through Share Program
Major Changes in Store for Canada-US Treaty
The Perils of Challenging an Equitable Result
A "Beneficial" Approach to Treaty Interpretation
Proposed Tax Amendments Remove Obstacle to Defeasance Transactions in Canada
Elimination of Withholding Tax on Conventional Interest Payments to Arm's Length Non-Residents
Your guide to the transfer pricing impact of the new Canada-US Protocol
Accelerated Elimination of Non-Resident Withholding Tax on Conventional Interest Payments
New Protocol to the Canada-US Tax Treaty: "Treaty Shopping" Limitations Expanded
New Protocol to Canada-U.S. Tax Treaty – Elimination of Withholding Tax on Interest and Other Changes
The Taxation of Commercial Enterprises and Business Transactions in Canada
Proposed Tax Amendments Remove Obstacle to Defeasance Transactions
Canada Chapter in Getting the Deal Through - Mining 2007
New Tax Reporting Requirements Proposed for Publicly Listed Mutual Fund Trusts and Partnerships
Amendments Would Remove Obstacle to Defeasance Transactions
Double dips frustrate Canadian finance minister
Income Trusts Cope with Upheaval
Big changes on the horizon for income trusts
Christmas in July? Corporate Tax Reductions Unveiled
Federal Budget 2006: Resurrection of the Super Flow-Through Share Program
Tax-Efficient Structuring in Canada: Choice of Entity Considerations and the Expanding Dynamic of the Unlimited Liability Company
When the Tax Tail "Doesn't" Wag the Business Dog
Proposed Legislation Shifts Focus Away From Income Trusts
An Unbiased Look at Unlimited Liability Companies in Canada
Taxpayers should look carefully at the treatment of child support payments
Canadian Government Unveils Initiative to Combat 'Aggressive' Tax Planning
Government Eliminates Foreign Property Restrictions on Retirement Savings Plans - Country Survey - Canada
Wood. v. Holden: Clarifying the "Central Management and Control" Test
Mining for Tax Incentives: The Rise of Flow-Through Share Offerings - Country Survey - Canada
Tsunami Relief Effort - 2004 Deadline Extended for Charitable Donations
Outlays, Expenditures, and Expenses: Grappling with the Proper Characterization of Employee Stock Options
Voluntary Disclosure Programs: Recent Trends and Developments
Tax-Efficient Lending into Canada: Dispelling the Myths
Tax-Efficient Investing in Canada: Dispelling the Myths
Ontario Government Releases Inaugural Budget
Government Releases Inaugural Budget
Government Extends Tax Collection Limitation Period
Canadian Minister of Finance Tables 2004 Federal Budget
General Anti-Avoidance Rule Interpreted Favourably
If It Seems Too Good To Be True... Department of Finance Releases New Legislation Restricting Charitable Donation Arrangements
Tax Court Releases Troubling Ruling on Complex Financial Transactions
New FIE Rules Address Accounting, Technical Issues
Department of Finance Release New Charitable Donation Rules; Penalties on Non-Resident Persons in Respect of Certain Dispositions
The Income Tax Treatment of Merger Costs: BJ Services Triumphs Again
Tax Treaties Update
Corporate Tax Rates Increased in Largest Province; Revenue Authority Sets Sights on "Treaty Shopping" Arrangements
The Rise and Fall of the Cross-Border Income Trust and What Lies Beyond…
The Queen v. Nova Scotia Power Inc. - The "Powerful" Perils of Section 173 of the Income Tax Act
BJ Services Company Canada v. The Queen - Capital Confusion: The Evolving Tax Characterization of Merger Costs
Nonresidents Beware: Restrictions on Canadian Tax Refunds
Recent Shifts in Capital Taxation in Canada
Winds of Change: Recent Shifts in Capital Taxation in Canada
The "Powerful" Perils of Section 173 of the Income Tax Act
Collateral Damage: GST and Income Taxation of Settlements and Release Payments
Is "Art" in the Eye of the Beholder? Baseball, Broadcasting, and the Interpretation of Tax Treaties
"Power"ful Agents: the Tax Treatment of Privatized Entities

Education

  • University of Toronto, MBA - 2000
  • University of Toronto, LLB - 2000

Year Of Call

  • Called to the Ontario bar - 2002

Practices

investment funds and asset management
tax
business taxation
charities/not-for-profit/tax-exempts

Directorships and Professional Associations

  • Canadian Tax Foundation

Teaching Engagements

  • Adjunct Faculty – "Integrative Legal Strategy" – Rotman School of Management at the University of Toronto - 2005-2006

Community Involvement

Michael is a strong supporter of a number of charitable causes and pro bono initiatives. Most notably, Michael is actively involved in the Family Legal Health Program, a joint pro bono initiative between McMillan LLP and Pro Bono Law Ontario that provides free legal services to patients of the Hospital for Sick Children in Toronto and their families.

Awards & Rankings

Media Mentions

vcard
Michael is a tax partner and Co-Chair of the firm's Tax Group. Michael advises clients on a diverse range of domestic and international taxation matters and has specialized expertise in structuring domestic and multi-national commercial acquisitions, divestitures, reorganizations and business combinations. Michael counsels clients on the tax elements of all major aspects of ongoing business operations, including employee compensation and stock option planning, tax and reporting compliance, transfer pricing, and voluntary disclosures.

Michael regularly counsels investment funds and asset managers on the establishment and administration of tax-efficient investment vehicles. Michael has been an active member of the McMillan Tax team that has stood at the forefront of the development of tax-efficient investment fund structures, including Master-Feeder funds, switch funds, and specialized return funds. Michael has assisted with the formation of a large number of institutional and specialized structured products catering to a wide range of domestic and offshore investors, specialized portfolios, and investment techniques, and advises a variety of domestic investment managers retained by international investment funds.

Michael regularly advises clients on the taxation and efficient structuring of hedging transactions, derivative instruments, securities lending arrangements, and repo transactions.

Michael has broad experience, and has enjoyed great success, representing clients in resolving tax disputes with both the Canada Revenue Agency and the provincial revenue authorities. Michael has appeared before both the Tax Court of Canada and the Federal Court of Appeal.
  • Acted for Public Mobile Inc. in connection with the acquisition of the telecommunication company by Thomvest Seed Capital Inc.
  • Acted for Detour Gold Corporation in its approximately $84 million acquisition of Trade Winds Ventures Inc. by way of a plan of arrangement
  • Acted for the underwriting syndicate in a bought deal equity offering for Perseus Mining Limited with gross proceeds of $93.4 million
  • Acted for Goldstone Resources Inc. in the approximate $104 million purchase thereof by Premier Gold Mines Limited
  • Acted for the dealer managers in connection with a $1.18 billion rights offering by Ivanhoe Mines Ltd.
publications
November 23, 2015
Significant Tax Changes on the Horizon
Tax Bulletin
October 2013
Hong Kong - Canada Tax Treaty in Force
Tax Bulletin
October 2013
Canada: Audit Guide
World Transfer Pricing 2014 - International Tax Review
March 2013
Budget 2013: synthetic dispositions
Tax Bulletin
November 2011
The New RRSP/RRIF Anti-Avoidence Regime
Taxation of Executive Compensation and Retirement Vol. 23(4)
Co-Authored with Todd Miller and Carl Irvine
September 2011
Securing & Sustaining "Mutual Fund Trust" Status – Tips & Traps - Part 2
Portfolio Management Association of Canada Seminar
June 2011
Employee Stock Options: New tax withholding requirements
Canadian Bar Association Business & Corporate Bulletin
May 2011
Canada Revenue Agency Releases New Treaty Eligibility Forms
Worldwide Tax Dailies
Co-authored by Michael Friedman and Ashley Palmer
May 2011
An Overview of the Canada Revenue Agency's Voluntary Disclosures Program
Estates, Trusts & Pensions Journal (2011) Vol. 30, No. 3
Co-authored by Michael Friedman and Ashley Palmer
March 2011
Coming Clean to the CRA: An Introduction to the Federal Voluntary Disclosures Program
Canadian Bar Association Business & Corporate Bulletin
December 2010
The Federal Court of Appeal - Ambiguity Resolved: Non-Resident Corporations that late-file Nil Returns Subject to Penalties
Canadian Tax Journal (2010) Volume 58, No. 4.  
Co-authored by Michael Friedman and Ashley Palmer
November 2010
Canada's New Tax Return Filing Requirements for Partnerships
Tax Notes International
November 2010
Transfer Pricing Documentation Requirements
Co-Presented by Michael Friedman and Todd Miller
at Federated Press: Basics of International Tax & Transfer Pricing
October 2010
Are you Eligible to Make a Valid Voluntary Disclosure?
Taxation Law Section, OBA Newsletter, Volume 21, No. 1
October 2010
U.S. Tax-Exempts and Article XXI of the Canada-U.S. Treaty: Claiming an Exemption from Canadian Withholding Tax
Journal of International Taxation, Volume 21, No. 10
Co-authored by Michael Friedman and Ashley Palmer
September 2010
Ambiguity resolved: Canadian Federal Court of Appeal upholds late-filing penalties for non-residents
Tax Planning International Review – Volume 37, Number 9 – Co-authored by Ashley Palmer and Michael Friedman
July 2010
Canada chapter in: Getting the Deal Through - Mining 2010
Reproduced with permission from Law Business Research. First published in Getting the Deal Through - Mining - 2010, (published in June 2010). For more information visit www.GettingTheDealThrough.com
November 2009
Canadian Court Upholds Late-Filing Penalties for Nonresident Corporations
Tax Notes International, Volume 56, Number 6
Co-authored by Michael Friedman and Ashley Palmer
July 13, 2009
Canadian Late Filing Penalty Successfully Challenged
Tax Notes International
Winter 2009
Canada and the U.S. Ratify Significant Tax Treaty Changes
Michigan Tax Lawyer, Volume XXXV, Issue 1, Winter 2009
Co-authored by Michael Friedman and Todd Miller
September 2008
Transfer Pricing Documentation Requirements in Canada
North American Transfer Pricing Solutions
Co-authored by Michael Friedman and Todd Miller
July 2008
Canada chapter in Getting the Deal Through – Mining 2008
Contributing editors: Sean Farrell, Robert McDermott and Jeffery Snow
Getting the Deal Through – Mining 2008For more information visit www.GettingTheDealThrough.com
April 2008
Canada reduces tax reporting for non-residents
International Tax Review
Co-authored by Michael Friedman and Todd Miller
March 2008
Transfer Pricing Documentation Guide
TP Weekly
March 2008
Budget 2008: Budget promises to lessen tax reporting burden on foreign-based private equity funds investing in Canada
Practical US/International Tax Strategies (WT Exec)
March 2008
Canadian Government to Lessen Tax Reporting Burden on Non-Residents
International Tax Review
January 2008
Major Changes in Store for Canada-US Treaty
International Tax Review, December/January 2008
Co-authored by Michael Friedman and Todd Miller
2008
The Perils of Challenging an Equitable Result
Canadian Tax Journal 56:1 Can Tax J 160
2008
A "Beneficial" Approach to Treaty Interpretation
Canadian Tax Journal 57:4 Can Tax J 871
Co-authored by Michael Friedman and Ashley Palmer
Winter 2008
Proposed Tax Amendments Remove Obstacle to Defeasance Transactions in Canada
CMBS World 10:4 (Winter 2008) 46
Co-authored by Michael Friedman, Robert Antenore and Stephanie Robinson
September 2007
The Taxation of Commercial Enterprises and Business Transactions in Canada
Chapter 9 in "Corporate Finance for Canadian Executives", edited by Howard E. Johnson (Carswell - Thomson Canada Limited - 2007)
July 2007
Amendments Would Remove Obstacle to Defeasance Transactions
Tax Notes International Volume 47, Number 2
Co-authored by Michael Friedman, Robert Antenore and Stephanie Robinson
June 2007
Double dips frustrate Canadian finance minister
International Tax Review
Co-authored by Michael Friedman, Todd Miller and John Galambos
February 2007
Income Trusts Cope with Upheaval
International Tax Review
Co-authored by Michael Friedman and Todd Miller
November 2006
Big changes on the horizon for income trusts
Law Times, Volume 17, Number 36
Co-authored: Michael Friedman and Todd Miller
Winter 2006
Tax-Efficient Structuring in Canada: Choice of Entity Considerations and the Expanding Dynamic of the Unlimited Liability Company
Michigan Tax Lawyer, Volume XXXII, Issue 1
Co-authored by Michael Friedman, Michael Domanski, Todd Miller and Wayne Gray
2006
When the Tax Tail "Doesn't" Wag the Business Dog
Canadian Tax Journal (2006) 54:3 Can Tax J 719
September 2005
An Unbiased Look at Unlimited Liability Companies in Canada
Tax and Corporate Law Bulletin
September 2005
Taxpayers should look carefully at the treatment of child support payments
The Lawyers Weekly
Co-authored: Michael Friedman and Sandy Andreou
September 2005
Canadian Government Unveils Initiative to Combat 'Aggressive' Tax Planning
Tax Planning International Review, Volume 32, Number 9
Co-authored by Michael Friedman and Matthew Langford
August 2005
Government Eliminates Foreign Property Restrictions on Retirement Savings Plans - Country Survey - Canada
Tax Planning International Review, August 2005
Co-authored by Michael Friedman and Stephen Genttner
August 2005
Wood. v. Holden: Clarifying the "Central Management and Control" Test
Tax Planning International Review, August 2005
Co-authored by Michael Friedman, Alexander Pizale and Chris Hughes
June 2005
Mining for Tax Incentives: The Rise of Flow-Through Share Offerings - Country Survey - Canada
Tax Planning International Review, Volume 32, Number 6
Co-authored by Michael Friedman and Matthew Langford
2005
Outlays, Expenditures, and Expenses: Grappling with the Proper Characterization of Employee Stock Options
Canadian Tax Journal (2005) 53:2 Can Tax J 463
October 2004
Voluntary Disclosure Programs: Recent Trends and Developments
Taxation Law, Volume 15, Number 1
Co-authored by Michael Friedman and Sacha Isaacksz
June 2004
Ontario Government Releases Inaugural Budget
Tax Planning International Review, Volume 31, Number 6
May 2004
Government Releases Inaugural Budget
World Corporate Finance Review, Volume 4, Number 5
Co-authored by Michael Friedman and Neal Hewitt
April 2004
Government Extends Tax Collection Limitation Period
World Corporate Finance Review, Volume 4, Number 4
March 2004
General Anti-Avoidance Rule Interpreted Favourably
World Corporate Finance Review, Volume 4, Number 3
February 2004
Tax Court Releases Troubling Ruling on Complex Financial Transactions
World Corporate Finance Review, Volume 4, Number 2
Co-authored by Michael Friedman and David Wentzell
January 2004
New FIE Rules Address Accounting, Technical Issues
Tax Notes International, Volume 33, Number 3
Co-authored by Michael Friedman and David Wentzell
January 2004
Department of Finance Release New Charitable Donation Rules; Penalties on Non-Resident Persons in Respect of Certain Dispositions
World Corporate Finance Review, Volume 4, Number 1
2004
The Income Tax Treatment of Merger Costs: BJ Services Triumphs Again
Canadian Tax Journal (2004) 52:1 Can Tax J 153
January 2004
Tax Treaties Update
Tax Planning International Review, Volume 31, Number 1
December 2003
Corporate Tax Rates Increased in Largest Province; Revenue Authority Sets Sights on "Treaty Shopping" Arrangements
World Corporate Finance Review, Volume 3, Number 12
September 2003
The Queen v. Nova Scotia Power Inc. - The "Powerful" Perils of Section 173 of the Income Tax Act
Canadian Tax Journal (2003) Vol. 51, No. 3, p. 1296
July 2003
Nonresidents Beware: Restrictions on Canadian Tax Refunds
Tax Notes International, Volume 31, Number 4
Co-authored by Michael Friedman and Andrea Leong
June 2003
Recent Shifts in Capital Taxation in Canada
Tax Notes International, Volume 30, Number 11
Co-authored by Michael Friedman and Hong Ky Luu
May 2003
Winds of Change: Recent Shifts in Capital Taxation in Canada
Taxation Law, Volume 13, Number 4
Co-authored by Michael Friedman and Hong Ky Luu
2003
The "Powerful" Perils of Section 173 of the Income Tax Act
Canadian Tax Journal (2003) 51:3 Can Tax J 1296
November 2002
Collateral Damage: GST and Income Taxation of Settlements and Release Payments
Taxation Law, Volume 13, Number 2
Co-authored by Michael Friedman and Jamie Wilks
2002
Is "Art" in the Eye of the Beholder? Baseball, Broadcasting, and the Interpretation of Tax Treaties
Canadian Tax Journal (2002) Vol. 50, No. 4
2002
"Power"ful Agents: the Tax Treatment of Privatized Entities
Canadian Tax Journal (2002) Vol. 50, No. 2
presentations
November 2015
Canadian Investor in an Increasingly Globally Regulated World
PMAC National Conference & Annual Meeting, Toronto, Ontario
November 2015
The Characteristics and Uses of Limited Partnerships
Osgoode Professional Development: The Short Course on Partnerships, Limited Partnerships and Joint Ventures, Toronto, Ontario
October 2015
Associated Affiliated and Related: The Implications
Ontario Tax Conference, Canadian Tax Foundation, Toronto, Ontario
October 2014
FATCA Workshop for Portfolio Managers
Portfolio Management Association of Canada, Co-presented with Deloitte, Amoranto Consulting, and Kaye Scholer LLP
September 16, 2014
FATCA: A Portfolio Manager's Guide to Navigating Uncharted Waters
Compliance Officers' Network Meeting, Portfolio Management Association of Canada
April 2014
The Future of Business Taxation in Canada: An Insider's Perspective
Canadian Corporate Counsel Association
March 2014
Crossing the 49th Parallel: Best Practices in Canada-US Corporate Transactions
Association of Corporate Counsel, Co-presented with Edwards Wildman
September 2013
Emerging Managers Seminar Series: Doing Business Offshore
Alternative Investment Management Association, Co-presented with KPMG, Walkers and Waratah Capital Advisors
November 5, 2012
Transfer Pricing Documentation Requirements
Co-Presented by Todd Miller and Michael Friedman, at Federated Press: 8th Understanding Canada/U.S. Transfer Pricing Course
October 16, 2012
Key Tax Issues for Corporate Counsel: Identifying and Managing Tax Risk
Corporate Counsel Tax Presentation, McMillan LLP
September 2012
Navigating the Minefield: An Advisor's Guide to Penalty Taxes and Other Tax Pitfalls
Presentation to the IAIC Annual Conference
February 2012
Taxation of Franchises: From Home and Abroad
Presented at the Canadian Franchise Association 2012 Legal Day
November 2011
Transfer Pricing Documentation Requirements
Co-Presented by Todd Miller and Michael Friedman, at Federated Press: 7th Understanding Canada/U.S. Transfer Pricing Course
September 2011
Securing & Sustaining 'Mutual Fund Trust' Status - Tips & Traps
Portfolio Management Association of Canada Seminar
October 2010
The Characteristics and Uses of Limited Partnerships
Osgoode Professional Development: The Short Course on Partnerships, Limited Partnerships and Joint Ventures, Toronto, Ontario
October 2009
The Characteristics and Uses of Limited Partnerships
Osgoode Professional Development: The Short Course on Partnerships, Limited Partnerships and Joint Ventures, Toronto, Ontario
May 2008
Challenges when Structuring Cross-Border Transactions and Political Solutions
Presented at the AIJA May Conference, Miami, Florida
June 2007
Income Trusts Revisited: The Canadian Income Tax Implications of the Proposed "SIFT" Rules
Federated Press: Tax Effective Private Equity & Investment Funds Course, Toronto, Ontario