Adrienne Oliver's practice involves all aspects of tax planning and implementation, primarily in the corporate tax field. Ms. Oliver is Co-Chair of our tax team.
She has participated in structuring major public and private transactions, reorganizations and financings, and has also acquired significant experience in international tax planning and public capital market transactions. Ms. Oliver has acted for clients in a diverse range of industries, including some of Canada's most respected corporations. She has recently acted in take-over, spinoff, joint venture and restructuring transactions.
In addition, Ms. Oliver has acted for major North American financial institutions and other issuers in connection with both domestic and cross-border debt or equity securities offerings.
Selected client work
Ms. Oliver's recent transactions include acting for:
ˇ Royal Bank of Canada in connection with the launch of its prospectus-qualified continuous distribution program for structured notes (senior debt), the offering in Canada of covered bonds in aggregate amounts of $750 million (November 2009) and $850 million (due March 16, 2015), the offering of US$1.5 billion of covered bonds under Rule 144A in the United States, on a private placement basis in Canada, and in Europe, and the prospectus-qualified offering in Canada of $1.5 billion of Series 14 Medium Term Notes (subordinated indebtedness)
ˇ Wajax Income Fund in connection with a secondary offering by ECL Western Holdings Limited and The Sobey Foundation of Fund units for $127 million
ˇ The syndicate of underwriters, led by Dundee Securities Corporation, in connection with a $15 million "bought deal" private placement of flow-through common shares of Sabina Gold & Silver Corp. in Canada and a "bought deal" public offering of common shares of Sabina Gold & Silver Corp.
ˇ Nortel in connection with its multijurisdictional insolvency proceedings including its agreement to sell its global Carrier VoIP and Application Solutions (CVAS) business to GENBAND
ˇ Mega Uranium Ltd. in connection with the company's first public financing, an offering of $50 million of Units, each Unit being comprised of one common share and one-half of one common share purchase warrant and in connection with the sale of its South American assets (together with $4 million) to U3O8 Corp. in exchange for 30.5 million shares of U3O8 and subsequent dividend-in-kind of such U3O8 shares to Mega's shareholders
ˇ Aeroplan Canada Inc. in connection with a $600 million secured credit facility entered into by Aeroplan as a lender, which facility provided financing to Air Canada
ˇ CHC Helicopter Corporation in connection with its $3.7 billion acquisition by an affiliate of a fund managed by First Reserve Corporation
ˇ Alcan Inc. in connection with the spinoff of Novelis Inc. to its shareholders and in the subsequent acquisition of Alcan Inc. by Rio Tinto plc
ˇ Bowater Inc. in its merger with Abitibi Consolidated
ˇ Cerberus Capital Management, L.P. in its acquisition of convertible preferred shares of Air Canada Enterprises in connection with Air Canada's restructuring and in its proposed acquisition of BCE Inc.
Speaking engagements
ˇ Speaker at conferences on a variety of tax-related issues
Rankings and recognitions
ˇ Chambers Global: The World's Leading Lawyers for Business, 2011: Tax
ˇ PLC Which lawyer?, 2011 - Tax
Memberships and activities
ˇ Law Society of Upper Canada
ˇ Ontario Bar Association
ˇ Canadian Tax Foundation
ˇ International Fiscal Association
ˇ Former instructor in Taxation, Ontario Bar Admission Course
Related Publications
Canada - Federal Budget June 2011 - new budget, same measures
On June 6, 2011, the Canadian federal government tabled a budget containing the same income tax measures as in its budget delivered on March 22, 2011.
07/06/2011
Harmonized sales tax and important changes to Canadian sales tax rules
Recent sales tax amendments at both the provincial and federal level have key implications for the manner in which companies charge and collect sales tax in Canada and in some cases restrict the ability of companies to claim credit for tax otherwise recoverable.
25/10/2010
Federal Budget 2011 - income tax measures
Budget 2011 contains no changes to corporate and personal income tax rates and does not propose to withdraw any previously announced planned reductions in income tax rates.
23/03/2011
Important changes to tax rules governing employee stock options: should you change your stock option plan?
On March 4th, 2010, the Canadian federal government tabled its Budget. Included in Budget 2010 are several important proposed amendments to the tax treatment of employee stock options under the Income Tax Act (Canada)
01/04/2010
GST/QST on investment manager fees
On April 16, 2009 the Federal Court of Appeal released its decision in the case of The Queen v The Canadian Medical Protective Association, which dealt with whether fully-discretionary investment management services were taxable supplies subject to GST.
18/12/2009
Online income of eBay sellers taxable
The recent announcement by Minister of National Revenue Jean-Pierre Blackburn confirming that the Canada Revenue Agency
04/08/2009
Protocol Amending the Canada-US Tax Treaty Enters Into Force
Last month, the Canadian Minister of Finance and the US Treasury Secretary announced the entry into force of the Fifth Protocol to the Canada-United States Income Tax Convention, 1980
06/01/2009
2009 Ontario budget
On March 26, 2009 the Ontario Government tabled its 2009 Budget. This Bulletin summarizes the principal tax measures contained in the Budget.
27/03/2009
Ontario government introduces the ideas for the future act
On September 23, the Ontario government released the Ideas for the Future Act, 2008,1 fulfilling a promise included in the 2008 Ontario Budget to provide a 10-year Ontario corporate tax holiday2 for new corporations that commercialize intellectual...
08/10/2008
Federal Budget 2009
On January 27, 2009, the federal government tabled its much-anticipated Budget. This Bulletin summarizes the principal income tax measures contained in the Budget and highlights certain non-income tax measures. Although the Budget contains a great deal of economic stimulus for virtually every
28/01/2009
Finally some relief - elimination of Section 116 Certificate Requirements and Canadian Income Tax on gains from sale of certain shares by non-residents
On March 4, 2010, the Canadian federal government tabled its Budget. Included in the Budget is a proposal which would eliminate, with effect from March 5, 2010, what has been a longstanding thorn in the side of foreign private equity and venture capital investors.
05/03/2010
Federal Budget 2010 - Income tax measures
On March 4, 2010, the federal government tabled its Budget. This bulletin summarizes the principal income tax measures affecting businesses contained in the Budget.
04/03/2010
Related News
Canada considers changing taxation of SIFTs
Adrienne Oliver discusses proposed amendments to specified investment flow-through (SIFT) entities in Canada with Anne Szustek of International Tax Review.
01/08/2011
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.
16/07/2008