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Expertise

Tax

Effective tax planning is key to many business transactions. Globalization,has resulted in tax issues becoming more complex and multi-jurisdictional than ever before.

Clients rely on our ability to structure innovative transactions that minimize tax costs and maximize results. Our tax team plays an integral role in advising clients on mergers, and acquisitions, corporate finance, and other tax-sensitive transactions.

In addition, clients benefit from our expertise in:

  • Domestic and international corporate tax planning
  • Tax dispute resolution and litigation
  • Executive compensation and benefits plans
  • Personal tax planning
  • Estate planning for high net worth individuals
  • Commodity taxes
  • Transfer pricing

We provide pragmatic tax advice that is insightful, creative, and tailored to protect each client's business interests. As an additional benefit, we cultivate and maintain contacts with tax authorities at all levels of government, and help clients remain informed on the changing tax issues that impact their business.

Services
  • Commodity taxes/customs matters
  • Corporate tax
  • Domestic and international tax planning
  • Estate planning and wealth management
  • Executive compensation and benefits plans
  • Merger and acquisition tax planning
  • Tax litigation
  • Transfer pricing
  • Trusts

Client Work
Cirque du Soleil in New Partnership with Dubai World

Acted for Cirque du Soleil in the acquisition of a 20% stake by Istithmar World and Nakheel, units of Dubai World.  More

RBC to Offer Up to ZAR 15M Royal Bank of Canada Fixed Rate Deposit Notes in the Uridashi Market

Canadian counsel to Royal Bank of Canada in connection with the offering in Japan of up to ZAR 15m Fixed Rate Deposit Notes due November 1, 2010.  More

Royal Bank of Canada Completes Issue of ZAR 30M Fixed Rate Deposit Notes in Uridashi Market

Counsel to RBC in issuing ZAR 30,000,000 (approx. CDN$4,398,000) Royal Bank of Canada Fixed Rate Deposit Notes due November 15, 2011.  More

Basell Sells its Corunna Site to Shell Chemicals

Counsel to Basell Canada in connection with the sale of certain assets to Shell Chemicals Canada.  More

Domtar Enters Agreement to Sell its Forest Products Business for Approximately $285M

Counsel to Domtar Corporation in its agreement for the sale of its forest products business to the newly created Conifex Inc. for approximately $285 million including an estimated $50 million of working capital.  More

Andlauer Management Group Proposes to Acquire ATS Income Fund

Counsel to Andlauer Management Group Inc. in connection with its proposed acquisition of ATS Andlauer Income Fund.  More

Visa Canada Integrates with Visa International

Represented Visa Canada in Visa enterprise's 2007 global restructuring program.  More

Four Seasons Hotels Privatization

Four Seasons Hotels Inc. was taken private by affiliates of Cascade Investment, L.L.C., Kingdom Hotels, and Isadore Sharp in a transaction valued at US $3.8 billion.  More

Québec Issues $1 Billion in Global Notes Series QG

Represented the underwriters in Quebec's issuance of US$1 Billion in Global Notes.  More

RBC Issues AUD 100M of 8.5 % Deposit Notes

Represented RBC in its issuance of AUD 100M of Deposit Notes.  More

RBC Completes Issue of €3 Billion of 5.75 % Deposit Notes

Counsel to RBC in its issuance of €3 Billion of Deposit Notes.  More

RBC Renews its $40 Billion Programme for the Issuance of Notes

Canadian and EU securities counsel to RBC in renewing its programme for the issuance of notes.  More

RBC Issues Samurai Bonds

Acted as Canadian Counsel to RBC in its issuance, in Japan, of Yen Bonds.  More

Bowater Merges with Abitibi Consolidated

Represented Bowater Inc. in the final step of its merger with Abitibi-Consolidated  More

Videotron Completes US$455 Million Private Placement of Senior Notes

Counsel to Videotron Ltd., the third largest cable operator in Canada, in connection with its completion of a US$455 million private placement of senior notes.  More

The Brock Group Acquires All Outstanding Securities Of Steeplejack Industrial Group Inc.

Acted as Canadian counsel for The Brock Group in connection with its successful $122 million acquisition of all of the outstanding securities of Steeplejack Industrial Group.  More

Mecachrome Initiates IPO

Advised Mecachrome International Inc., for both the Canadian and U.S. aspects of the transaction, in its filing of a final prospectus for an initial public offering.  More

Quebecor World Inc. Issues High Yield Senior Notes

Advised Quebecor World Inc. on its high-yield offering of US$400 million 9¾% Senior Notes due January 15, 2015, which were issued and sold on a private placement basis in the United States and to a limited number of accredited investors in  More

JDSU Acquires Innocor

Acted for Innocor, a provider of broadband test solutions for network equipment manufacturers, in its acquisition by JDSU.  More

Goldman Sachs Capital Partners Finances CanWest MediaWorks Purchase of Alliance Atlantis Communications

On January 10, 2007 Goldman Sachs Capital Partners and CanWest MediaWorks announced CanWest MediaWorks' agreement to purchase Alliance Atlantis Communications.  More

Yellow Pages Group Acquires Print and Online Directory and Directory Data Services Business of MTS Allstream

Represented Yellow Pages Group (YPG) in its $275 million acquisition of the print and online directory and directory data services business of MTS Allstream, a wholly-owned subsidiary of Manitoba Telecom Services.  More

Bank of America, N.A., Finances BCBG Max Azria Group Inc. and BCBG Max Azria Canada Inc.

Acted as counsel to Bank of America, N.A., as agent and lender, in the US$187 million and CAN$12 million financing of BCBG Max Azria Group, Inc. and BCBG Max Azria Canada Inc.  More

Rio Tinto Acquires Alcan

Ogilvy Renault represented Alcan in its recently completed US$38.1 billion offer of acquisition.  More

SGF Takes Part in TPG Capital's $1.3-Billion Privatization of Axcan Pharma

Société générale de financement announced that it would invest $60 million directly into Axcan Pharma Inc. debt and equity.  More

Quebecor Media Successfully Completes its Privatization of Nurun Inc.

Acted as counsel to Quebecor Media in the context of a take-over bid. The total value of the transaction was approximately $76 M.  More

Yellow Pages Group Acquires TBayTel

Acted as counsel to Yellow Pages Group Co. in the $17M acquisition of the telephone directories business of TBayTel.  More

KR Wind Holdings (Canada) Inc. Completes Purchase of 2064807 Ontario Inc., a private holding company for R.J.S. Mechanical Inc. and Q.C. Enterprise Inc.

The vendors, Robert and Janice Scoffield, were represented by Ogilvy Renault LLP with a team comprised of Michel Carle, Anthony Milazzo, Sarah Crossley and Fiorella Bellissimo.  More

Ogilvy Renault Acts for CHC in $3.7 Billion Deal

The largest ever buy-out in the oil field services industry  More

Royal Bank of Canada's Sale of $4 Billion of Six-Year Extendible Notes

Acted as Canadian counsel to RBC in connection with the sale of $4B of six-year extendible notes in a 144a private placement.  More

TVA Group Repurchases $51M in Class B Non-Voting Shares

Acted as counsel to TVA Group Inc. in its $51,000,000 offer to repurchase up to 3,000,000 of its Class B Non-Voting Shares under a substantial issuer bid.  More

Nortel Completes Offering of US$675 Million Senior Notes

Represented Nortel, in Canada, with regards to its offering of 10.75% Senior Notes due 2016.  More

Kendle International Inc. Acquires DecisionLine Clinical Research Corporation

Represented Kendle in its acquisition of DecisionLine through a wholly owned Canadian subsidiary.  More

National Bank of Canada Completes Public Offering of Preferred Shares

Represented underwriters in National Bank of Canada's public offering of $150 million of Non-Cumulative Fixed Rate First Preferred Shares.  More

Ogilvy Renault Represents the Shareholders of Thibodeau Group of Companies

TransForce Income Fund completed the acquisition of all of the shares of Groupe Thibodeau inc., a privately held company headquartered in Portneuf, Quebec.  More

Events
Institute of Law Clerks of Ontario Annual Conference 2008

Joan van Zant, Kelly Friedman, and Barry Segal present sessions on Navigating Your Way through the Patenting Process, The Sedona Canada Principles, and Demystifying Tax Rollovers.  More

Publications
Federal Budget 2008

On February 26, 2008, the Conservative Government tabled its third budget. Budget 2008 contains targeted corporate and personal income tax measures, as well as measures to improve the efficiency of the tax system.  More

Elimination of Withholding Tax on Arm's Length Payments of Interest

On December 14, 2007, the legislation to eliminate Canadian withholding tax on interest paid or credited to arm's length non-resident lenders became law.  More

New Effective Date for the Elimination of Withholding Tax on Interest

A Notice of Ways and Means Motion tabled in Parliament on November 13, 2007 has moved forward the effective date for the elimination of Canadian withholding tax on interest payments to arm's length non-resident lenders.  More

Update on Canada-US Tax Treaty - Hybrid Entities

On September 21, 2007, the Minister of Finance announced the signing of the Fifth Protocol to the Canada-United States Income Tax Convention, 1980 (the "Treaty"), which updates and amends certain provisions of the Treaty.  More

Highlights of the Quebec Budget 2007-2008

On May 24, 2007, the Quebec Minister of Finance, Monique Jérôme-Forget, tabled the Quebec Government's 2007-2008 Budget.  More

Cross-border Transactions: Proposed Elimination of Canadian Withholding Tax

On March 19, in its second budget, the federal Conservative Government announced significant measures to eventually eliminate withholding tax on interest paid by Canadian-resident corporate borrowers to arm's length non-residents...  More

Federal Budget 2007

On March 19, 2007, the Conservative Government tabled its second budget.  More

Highlights of the Quebec Budget 2007-2008

On February 20, 2007, the Quebec Minister of Finance, Michel Audet, tabled the Quebec Government's 2007-2008 Budget.  More

Supreme Court Denies Deduction for Foreign Exchange Losses on Foreign Currency Debt

On October 20, 2006, the Supreme Court of Canada issued its decision in the cases of Imperial Oil Ltd. v. The Queen and Inco Ltd. v. The Queen.  More

Ontario and Federal Government Sign Agreement for Combined Ontario Corporate Tax Administration - A Blessing and A Curse?

On October 6, 2006 the federal and Ontario Ministers of Finance signed an agreement under which the federal government will collect and administer Ontario's corporate income tax.  More

Canadian Withholding Tax on Loans Between Non-Residents

A non-resident planning to expand its business into Canada must decide whether to carry on the business directly (i.e., through a branch, partnership or joint venture) or to incorporate a Canadian subsidiary.  More

2006 Federal Budget Highlights

On May 2, 2006, the Conservative Government tabled its inaugural budget.  More

Federal government announces moratorium on providing advance income tax rulings on flow-through structures, including income trusts

On September 8, 2005, the federal government issued a paper and launched consultations with the public on the tax treatment of income trusts.  More

Recent Developments regarding Canadian Unlimited Liability Companies

US businesses that establish operations or acquire businesses in Canada often make use of a Canadian unlimited liability company (ULC). This newsletter highlights some recent ULC developments.  More

The Quebec Stock Savings Plan (QSSP) To Be Replaced by the SME Growth Stock Plan

In 1979, the Quebec Government introduced the Quebec Stock Savings Plan (QSSP) with the aim of helping Quebec companies to attract investor capital. Over the years, the Government restricted access to the plan and ultimately imposed a moratorium on its...  More

2005 Federal Budget Tax Highlights

As expected from this minority government, this Budget proposes changes that provide a little something for almost everyone.  More

Federal Budget Proposes New Tax Treatment for Non-Resident Holders of Mutual Funds

The 2004 Federal Budget proposes significant changes to the income tax treatment of non-residents who hold units of mutual fund trusts and shares of mutual fund corporations.  More

Trusts Provide Probate Planning Opportunities for Seniors

Avoiding probate has long been a key consideration in developing estate plans for individuals and their families.  More

Stock Options - Dealing with Declining Share Price

Stock option plans are effective compensation when share prices are rising. However, in a climate of declining share prices, stock options often require "repricing" in order to maintain their incentive effect.  More

Media Highlights
Chief Justice Bowman: Repertoire of a Jurist

Wilfrid Lefebvre is quoted in Lexpert magazine, where he reflects on the career of the Honourable Donald George Hugh Bowman, who recently retired as Chief Justice of the Tax Court of Canada.  More

Flaherty Says Canada's Energy Resources Will Buffer it From Global Slowdown

Adrienne Oliver was quoted in several Canadian news outlets talking about the unlikelihood of the federal government changing its stance on the controversial tax on income trusts.  More

Canada Says Trusts Can Convert Without `Undue' Taxes

Senior advisor and tax spokesperson Len Farber responds to the federal Finance Department's announcement on draft regulations to allow income trusts to be converted to corporations ''without undue tax effects'' for investors.  More

Still the Ones

Wilfrid Lefebvre, senior partner on the Tax team, is featured on the May cover of Lexpert magazine addressing the career longevity of senior tax litigators and the impact it has on young associates.  More

Ogilvy Renault Acting for Alcan in US$38.1B Deal with Rio Tinto

When it comes to Canada's biggest deals, Ogilvy Renault LLP is there. Our firm is representing Alcan on the US$38.1 billion offer of acquisition by Rio Tinto.  More

Domtar to sell its forest products business for approximately CDN$285 million

Domtar Corporation announced that it has entered into an agreement for the sale of its forest products business to the newly created Conifex Inc. for approximately CDN$285 million including an estimated CDN$50 million of working capital.  More

Tax Expert Len Farber Receives Distinguished Service Award

Ogilvy Renault's Len Farber, one of Canada's foremost authorities on tax policy and tax legislation, has received a distinguished service award for his career accomplishments and public service from the Tax Executives Institute Inc. (TEI) based in...  More

Ogilvy Renault LLP and Séguin Racine, Attorneys advising Garda in its acquisition of ATI Systems International to become second largest cash handling company in North America.

Ogilvy Renault LLP, along with Garda World Security Corporation's long-time legal counsel, Séguin Racine, Attorneys (Laval, Québec), are representing Garda in connection with its proposed acquisition of ATI Systems International to become the second ...  More

Ogilvy Renault represents Bowater Incorporated in merger with Abitibi-Consolidated Inc.

Ogilvy Renault, LLP acted as Canadian legal adviser to Bowater Incorporated (NYSE: BOW) in connection with its merger of equals with Abitibi-Consolidated Inc.  More

Ogilvy Renault LLP Represents Domtar in Largest Fine Paper Deal in North America

Ogilvy Renault acted as counsel to Domtar Inc. in their $3.3-billion (U.S.) combination with Weyerhaeuser Co.  More

Top Canadian Tax Official Len Farber to Join Ogilvy Renault

Ogilvy Renault LLP is pleased to announce that Len Farber will be joining the firm as a Senior Advisor on January 3, 2006.  More

Ogilvy Renault Appoints Adrienne Oliver As Tax Co-Chair

Ogilvy Renault LLP is pleased to announce that Adrienne Oliver has been appointed as Co-Chair of the firm's national Tax group.  More