Overview
Miller Thomson’s Corporate Tax Group provides legal advice, representation and cost-effective solutions to clients on a wide array of tax topics. Our lawyers come from a diverse background of education and experience, representing clients in many industry sectors, such as: manufacturing and processing, automotive, real estate, construction, banking and finance, computer equipment and software, oil and gas, the resource service sector, professional services, among others. We are also positioned at the forefront of rapidly growing technological areas, such as cleantech and greentech. Our lawyers are considered thought leaders on tax matters and are frequent speakers at the Canadian Tax Foundation, Canadian Bar Association and Society of Trust and Estate Practitioners conferences as well as author several tax related publications.
Our Corporate Tax expertise encompasses structuring and implementation of mergers and acquisitions (M&A) transactions and financing, reorganizations of public and private companies, investment funds, real estate investment trusts (REITs), income trusts and other entities, transfer pricing, international tax, cross-border taxation, executive compensation issues including stock option and benefit plans. We also regularly advise clients with respect to tax risks and tax filings. Our lawyers have been involved in a broad spectrum of transactions and planning activities including the following:
- Structuring and implementation of mergers, acquisitions and divestitures of Canadian public and private companies and other entities, including by Plan of Arrangement
- Structuring and implementation of going public and private transactions
- Structuring and advising on financing transactions including loan facilities and equity and debt offerings for Canadian and foreign issuers, investors, lenders and borrowers
- Structuring and implementation of take-over bids of Canadian companies and other entities
- Structuring cross-border and international investments in Canada and foreign jurisdictions
- Preparing and advising on tax disclosure in Management Information Circulars, Offering Memorandums, Prospectuses and Annual Information Forms for Canadian and foreign public and private companies, investment funds, REITS and income trusts regarding M&A, financing and reorganization transactions
- Structuring reorganization of public and private corporations, partnerships, investment funds, REITs and income trusts among others
- Structuring sales of businesses using exchangeable shares to maximize available tax deferrals
- Structuring the reorganization of a business to next generation and/or employee ownership
- Advising on flow-through share transactions to finance operations of mining companies
- Advising on the sale and leasing of oil and gas properties
- Advising and establishing structures to effectively use the Canada-US Tax Treaty and other tax treaties
- Advising on transfer pricing approaches, agreements and disputes
- Successfully arranging taxpayer voluntary disclosures
- Advising on rectification regarding tax related transactions
- Representing taxpayers in tax avoidance audits and appeals
- Advising municipal utilities on the tax consequences of privatization and competition
- Advising “Green Companies” on tax efficient structures including the use of federal and provincial tax credits
