Practice Areas & Industries: Borden Ladner Gervais LLP

Practice/Industry Group Overview

Our Tax Group is composed of some 30 professionals throughout Canada having a broad range of experience in the corporate tax, personal tax and estate planning, tax litigation and commodity tax fields.  Our seasoned tax professionals advise and assist clients in domestic and international transactions.

Members of our Tax Group have served in government and private industry tax departments, are active in numerous professional organizations including the Canadian Tax Foundation and the International Fiscal Association, regularly make submissions to government on tax laws, and write and lecture on taxation matters.

Our Experience

Our Tax Group acts for a diverse client base including Canadian and foreign firms on all relevant tax and trade law questions.  Recently our Tax Group has acted in the following matters:

• Acquisition of Cadillac Fairview Corporation by Ontario Teachers' Pension Plan Board
• Acquisition of Provigo Inc. by Loblaw Companies Limited
• Divestiture of E.B. Eddy Limited by George Weston Limited
• Acquisition of Scott's Restaurants Inc. by SR Acquisition Corporation
• Structuring and implementation of the Mackenzie Income Trust
• Worldwide spin off of Agilent Technologies by Hewlett-Packard
• Divestiture of Trans Canada Pipelines' midstream business 

Services Available

Our Tax Group provides practical, innovative and proactive tax services to a diverse client base.  These clients include public and private corporations, financial institutions, trust companies, mutual funds, pension funds, owner-operated businesses, individuals, trusts, estates, charitable foundations, accounting firms and foreign enterprises.  Our Tax Group works closely with other members of the Firm involved in commercial, financial, real estate, labour, litigation, corporate and wealth management matters.

Our Tax Group offers unique expertise and depth in all areas of corporate, international, personal and commodity taxation and in the tax litigation field and offers the following specialized services.

Corporate Tax Planning:

Mergers and acquisitions

Demergers and divestitures

Reorganizations and restructurings

Corporate loss utilization strategies

Structured financing transactions

Derivative products

Resource taxation

Mutual fund and pension fund planning

Taxation of E-commerce transactions

Tax matters relating to high tech industry

Employee compensation arrangements

Partnerships, joint ventures and trusts

International Tax Planning:

Transfer pricing

Structuring inbound and outbound investments

Cross-border joint venturing

Cross-border licensing, financing, holding and insurance structures

Foreign affiliates, foreign investment entities and foreign reporting rules

Non-resident withholding tax

Personal Tax Planning:

Transfer of assets and shares to a corporation (tax deferred rollovers)

Post mortem tax planning

Transfer of share ownership to employees, family members or other shareholders

Income splitting and estate freezing

Compensation of the owner-manager

Tax deferred retirement plans

Taxation of professionals

Maximizing the capital gains exemption

Shareholder buy-sell arrangements

Charitable donations and private charitable foundations

Emigration from and immigration to Canada

Offshore and domestic trusts

Tax Litigation:

Submissions respecting proposed assessments

Objections and appeals

Voluntary disclosures

Income tax audits and investigations

Commodity Taxation:

GST and provincial sales tax consequences on the sale and purchase of assets

GST and provincial sales tax consequences on the use of partnerships, trusts and joint ventures

GST and provincial sales tax on imports and exports

Tobacco tax

Fuel tax

Customs duties and excise taxes