Nutrien Ltd.

Acted as Canadian tax counsel to Nutrien Ltd. in respect of the sale to Tianqi Lithium Corporation of Nutrien's 62,556,568 "A shares" in the capital of Sociedad Química y Minera de Chile S.A. for consideration of $65 per share in cash, representing a total gross valuation of approximately US$4.07 billion.

Nutrien Ltd.

Acted as Canadian tax counsel to Nutrien Ltd. in the sale to SDIC Mining Investment Co. Ltd. of 23,294,614 common shares of Arab Potash Company for gross proceeds of $502 million.

Nutrien Ltd.

Acted as Canadian tax counsel for Nutrien Ltd. and its subsidiary, Potash Corporation of Saskatchewan Inc., in Nutrien's offer to exchange all outstanding publicly held notes of PotashCorp and Agrium Inc. for new notes to be issued by Nutrien.

Potash Corporation of Saskatchewan Inc.

Acted as Canadian tax counsel for Potash Corporation of Saskatchewan Inc. in its US$36-billion merger of equals with Agrium Inc. to create the world-class integrated global supplier of crop inputs, Nutrien Ltd. This deal was named 2017's Deal of the Year by Lexpert Magazine and won the Mining Deal of the Year award at the 2017 Canadian Dealmakers Awards.

International Petroleum Investment Company

Acted as Canadian tax counsel for International Petroleum Investment Company, an Abu Dhabi-based sovereign wealth fund, on its merger with Mubadala Development Company, creating the 14th largest state-owned investment fund in the world with $125-billion in combined total assets and businesses in over 30 countries.

Potash Corporation of Saskatchewan Inc.

Acted for Potash Corporation of Saskatchewan Inc., providing tax advice in connection with a US$500-million bond offering.

The Sentient Group

Acted for The Sentient Group in connection with the acquisition of Rio Madeira Comércio Importaçao e Exportaçao de Minérios, a Brazilian company operating a manganese mine. In relation to this acquisition, Sentient executed a binding term sheet with Cancana Resources Corp. whereby and pursuant to which Sentient acquired shares, warrants and convertible debentures of Cancana and the latter will subscribe for 50% of the quotas of Rio Madeira.

The Sentient Group

Acted for The Sentient Group with respect to its US$140-million divestiture of interest in Norsemont Mining Inc.

Potash Corporation of Saskatchewan

Acted for Potash Corporation of Saskatchewan with respect to offerings of US$500 million due 2017 and US$500 million due 2040.

Potash Corporation of Saskatchewan

Acted as Canadian tax counsel to Potash Corporation of Saskatchewan with respect to offerings of US$500 million due 2015 and US$500 million due 2020.

Potash Corporation of Saskatchewan

Acted for Potash Corporation of Saskatchewan Inc. which issued US$500 million notes due May 15, 2014 and US$500 million notes due May 15, 2019.

GMAC LLC

Acted for GMAC LLC as it completed US$38.146 billion outstanding notes exchange and purchase offers and separate offers to exchange and purchase outstanding notes of Residential Capital, LLC.

Vitol Refining Group B.V. & Vitol Refining S.A.

Acted for Vitol Refining Group B.V. on its sale of North Atlantic Refining Limited to Harvest Energy Trust in a transaction valued at $1.6 billion.

JP Morgan Partners, LLC

Acted for JP Morgan Partners, LLC and its affiliates in the sale of all the shares of Telesystem International Wireless Inc. for an aggregate amount of $830 million.

Kimco Realty Corporation

Acted for Kimco Realty Corporation, a leading U.S.-based publicly-traded REIT, in connection with a partnership with Sandalwood Management Canada Co. to acquire more than 1 million square feet of retail property comprised of six shopping centres in the Province of Québec.

Circuit City Stores, Inc.

Acted for Circuit City Stores, Inc. on its acquisition of InterTAN, Inc., the operator of Radio Shack stores in Canada, in a transaction valued at approximately US$286 million to create The Source.

Euro-Pro Corporation and Omega Sewmac Inc.

Acted for Euro-Pro Corporation and Omega Sewmac Inc. in regard to the sale of their businesses to Euro-Pro Operating LLC and the related financing.

CIT Group

Acted for CIT Group in its $3-billion takeover bid for Newcourt Credit Group Inc.

Diamond Fields Resources

Acted for Diamond Fields, as well as one of its two major shareholders, in its $4-billion sale to Inco.

Canada Finally Enacts the Digital Services Tax (Maybe)

July 09, 2024 - The new Digital Services Tax Act came into force with an order-in-council on June 28, 2024, imposing a 3% digital services tax (DST) on certain Canadian-source digital services revenue of large entities. The DST would first be payable in 2025, with the initial payments retroactively...

Canada’s Enactment of Pillar 2 – Part I, co-author

July 01, 2024 - Tax Notes International, Volume 115, No. 1 (Tax Notes)
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Canada’s Digital Services Tax Move Still Sets Nothing in Stone, co-author

Dec. 14, 2023 - Bloomberg Tax (Bloomberg Industry Group, Inc.)
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US Developments May Raise Canadian Tax on US Owned Canadian Subs

Nov. 03, 2023 - Tax Management International Journal (Bloomberg Industry Group, Inc.)
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Government of Canada Releases Package of Proposed Domestic and International Tax Legislation

Aug. 16, 2023 - The Department of Finance (Finance) released draft tax legislation for public consultation on August 4, 2023, with a stated focus on promoting tax fairness and a clean economy. The most significant item released is the draft of a major new statute, the Global Minimum Tax Act, spanning...

Canadian Federal Court of Appeal Gets Section 20(12) Right

July 17, 2023 - Tax Notes International (Tax Analysts)
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US Bill Attacking Foreign DSTs and UTPR Would Hit Canadians, co-author

July 06, 2023 - Tax Management International Journal (Bloomberg Industry Group, Inc.)
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Reconstructing EIFEL: Significant Amendments Introduced in November 2022 Revised Legislation, co-author

Feb. 01, 2023 - International Tax Highlights, Vol. 2, No. 1
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International Tax, co-author

Dec. 01, 2022 - Wolters Kluwer International Tax (Wolters Kluwer)
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SUTPR: Harmful Effects in Canada?

Nov. 04, 2022 - Tax Management International Journal, Vol. 51, No. 11 (The Bureau of National Affairs, Inc.)
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Withholding Taxes—A Baseless Pillar One Issue

Sept. 14, 2022 - Bloomberg Law News – Tax Insights & Commentary (The Bureau of National Affairs, Inc.)
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Senator Rob Portman’s Inadvertent, Profound Criticism of OECD’s 15% Global Minimum Tax

Sept. 02, 2022 - Tax Management International Journal, Vol. 51, No. 9 (The Bureau of National Affairs, Inc.)
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Highlights of Canada’s Latest Legislative Tax Proposals

Aug. 23, 2022 - The Department of Finance recently released a package of materials containing potential changes to the Canadian tax system (Tax Proposals). The materials, released on August 9, 2022, include draft amendments to the Income Tax Act (Tax Act) to implement certain measures from the 2022...

Hybrids in Canada and the United States: The BEPS Action 2-Based Response

July 01, 2022 - Tax Management International Journal, Vol. 51, No. 7 (The Bureau of National Affairs, Inc)
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Anti-Hybrid Rules Arrive (Finally) In Canada, co-author

June 20, 2022 - Tax Notes International, Vol. 106, No. 12 (Tax Analysts)
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Privately Owned Foreign Affiliates Caught in Canadian Budget Crossfire

June 03, 2022 - Tax Management International Journal, Vol. 51, No. 6 (The Bureau of National Affairs, Inc)
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Pillar Two : Effects on Canadian Multinationals

Apr. 01, 2022 - Tax Management International Journal, Vol. 51, No. 4 (The Bureau of National Affairs, Inc)
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Is the Tug of War Between the Senate and the U.S. Administration over BEPS Pillar One Jurisdiction at Least Partially Illusionary?, co-author

Mar. 04, 2022 - Tax Management International Journal, Vol. 51, No. 3 (The Bureau of National Affairs, Inc)
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Canadian Supreme Court Upholds Loblaw’s Offshore Bank Structure, co-author

Feb. 28, 2022 - Tax Notes International, Vol. 105, No. 9 (Tax Analysts)
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Viewpoint ‒ OECD Pillar 2: ʻ15 Percent Minimum Taxʼ Deal Will See Canada Reduce Or Cannibalize Its Own GDP

Nov. 15, 2021 - Tax Notes International, Vol. 104, No. 7 (Tax Analysts)
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The Evolution of U.S. Tax Rates and Related Matters Since 2017 ‒ in a Canadian Context, co-author

Nov. 05, 2021 - Tax Management International Journal, Vol. 50, No. 11 (The Bureau of National Affairs, Inc)
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Canada at the Crossroads of International Tax Reform: Between Harmonization and Tax Competition, co-author

Oct. 26, 2021 - Bulletin for International Taxation, Vol. 75, No. 11/12 (IBFD)
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Biden Proposal Would Dramatically Alter Longstanding U.S. Gift and Estate Tax Planning for Wealthy Families, co-author

July 02, 2021 - Tax Management International Journal, Vol. 50, Issue 7 (Bloomberg TAX)
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Canada and BEPS: What Goes Around Comes Round, co-author

June 28, 2021 - Tax Notes International, Vol. 102, No. 13 (Tax Analysts)
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The Emergis Hybrid Financing Case: Déjà Vu?, co-author

May 03, 2021 - Tax Notes International, Vol. 102, No. 5 (Tax Analysts)
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Supreme Court Confirms Cameco’s Epic Transfer Pricing Victory, co-author

Apr. 02, 2021 - Tax Management International Journal, Vol. 50, Issue 4 (Bloomberg TAX)

Cameco Goes to the Supreme Court: The Crown’s Appeal for Recharacterization Should Go Nowhere

Feb. 21, 2021 - Tax Management International Journal, Vol. 50, Issue 2 (Bloomberg TAX)

Relationship Between Cameco and Glencore Transfer Pricing Cases

Dec. 01, 2020 - International Tax Journal, Vol. 115 (Wolters Kluwer)
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The ‘Cameco’ Transfer Pricing Sequel: Government’s Appeal on Interpretation of Transaction Substitution Rule Rejected, co-author

Aug. 14, 2020 - Tax Management International Journal, Vol. 49, No. 8 (Bloomberg TAX)
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Québec Proposes North America’s First IP Box, co-author

June 29, 2020 - Tax Notes International, Vol. 98, No. 13 (Tax Analysts)
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Evaluating Canada’s Attempt to Reconcile General Transfer Pricing Rules and Specific Antiabuse Provisions, co-author

May 11, 2020 - Tax Notes International, Vol. 98, No. 6 (Tax Analysts)
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How Will Revised Sourcing Rules Affect Sales Of U.S.-Made Goods Abroad?

Feb. 10, 2020 - Tax Notes International, Vol. 97, No. 6 (Tax Analysts)
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Canadian Tax Laws: A Review of 2019 and a Look Ahead to 2020

Jan. 30, 2020 - Each year at this time we look back at some of the more significant income tax developments in Canada affecting domestic and international business over the past year and look ahead to possible Canadian tax developments in the coming year. Review of Canadian Tax Developments in 2019 Tax...

GILTI and Canadian CFCs Under Recent Regulations

Jan. 10, 2020 - Tax Management International Journal, Vol. 49, No. 1 (Bloomberg TAX)
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Glencore: Australian Court Relies on Cameco

Dec. 01, 2019 - International Tax Journal, Vol. 109 (Wolters Kluwer)
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Is Corporate Tax Abolition Unrealistic

Nov. 04, 2019 - Tax Notes International, Vol. 96, No. 5 (Tax Analysts)
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Letter to the Editor: Wealth Tax Proposals — Taxation or Confiscation?

Oct. 21, 2019 - Tax Notes International, Vol. 96, No. 3 (Tax Analysts)
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Canada Enacts Multilateral Instrument: What Happens Next?, co-author

July 22, 2019 - Tax Notes International, Vol. 95, No. 4 (Tax Analysts)
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Canada Enacts the OECD-Sponsored Multilateral Instrument

June 26, 2019 - Canada has enacted into law the OECD-sponsored Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The enactment of June 21, 2019 represents the penultimate step in the domestic ratification of the MLI in Canada, which will...

Proposed U.S. Regs Narrow GILTI Exposure on Canadian CFC Operations

June 03, 2019 - Tax Notes International, Vol. 94, No. 10 (Tax Analysts)
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Expected Adverse Effects of Proposed U.S. Anti-Hybrid Regulations on Inbound Financing By Canadian MNEx, co-author

Feb. 11, 2019 - Tax Notes International, Vol. 93, No 6 (Tax Analysts)
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Canada Finalizes International Tax Proposals: An Update on Conduit, Tracking, and Foreign Affiliate Rules

Dec. 03, 2018 - Tax Notes International, Vol. 92, No.10
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‘Cameco’: Canadian Counterpart of ‘E.I. Du Pont de Nemours’

Nov. 09, 2018 - Tax Management International Journal, Vol. 47, No. 11 (Bloomberg Tax)
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The Tax Court of Canada Strikes Offshore eBank in Loblaw, co-author

Oct. 29, 2018 - Tax Notes International, Vol. 92, No.5 (Tax Analysts)
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How U.S. Tax Reform Affects Canada-U.S. Tax Factors

Oct. 12, 2018 - Tax Management International Journal, Vol. 47, No. 10 (Bloomberg Tax)
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US Territoriality: A Promise Not Kept

May 01, 2018 - Canadian Tax Highlights, Vol. 26, No. 5
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The U.S.’s Illusionary Turn to Territoriality

Feb. 12, 2018 - In this article from Tax Notes International, Davies partner Nathan Boidman contends that the sponsors of the Tax Cuts and Jobs Act not only failed to deliver on their promise of a territorial system for controlled foreign corporations, but also expanded the pre-existing...

U.S. Tax Laws: A Review of 2017 and a Look Ahead to 2018

Jan. 11, 2018 - Each year at this time, we offer a look back at some of the more significant income tax developments in the United States affecting domestic and international business over the past year and a look ahead to possible U.S. tax developments in the coming year. Tax Developments in 2017 As we...

Canadian Tax Laws: A Review of 2017 and a Look Ahead to 2018

Jan. 11, 2018 - Each year at this time we offer a look back at some of the more significant income tax developments in Canada affecting domestic and international business over the past year and a look ahead to possible Canadian tax developments in the coming year. Developments in 2017 1....

The Univar Appeal: A Pyrrhic Victory For Indirect Acquisitions in Canada

Oct. 30, 2017 - In this article published in Tax Notes International, Davies partner Nathan Boidman reviews the decision by the Federal Court of Appeal in Univar Holdco Canada ULC v. The Queen, particularly in the context of the 2016 Income Tax Act amendments concerning surplus...

Canada Persists With Plan to Punish Private Corporate Passive Reinvestment, co-author

Oct. 30, 2017 - Tax Notes International, Vol. 88, No. 5 (Tax Analysts)
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Unexpected Canadian Private Company Tax Proposals: A Critique And International Comparative

Sept. 04, 2017 - In this article from Tax Notes International, Davies partners Nathan Boidman and Michael Kandev examine proposed plans by the Canadian government for radical changes to the Income Tax Act ostensibly aimed at curbing tax planning using private corporations. Download this article.

Canada’s Limited Approach to the OECD’s MLI

July 03, 2017 - In this article published in Tax Notes International, Davies partners Nathan Boidman and Michael Kandev discuss Canada’s signing of the OECD multilateral instrument to adopt many of the anti-BEPS tax treaty rules. Download this article.

Canada’s Enhanced Transitional Rules for U.S. LLPs and LLLPs

June 15, 2017 - In this article from Tax Notes International, Davies partner Nathan Boidman provides updates about the Canada Revenue Agency’s May 26, 2016, non-binding administrative decision to treat certain U.S. limited liability partnerships (LLPs) and limited liability limited partnerships (LLLPs)...

Canadian and U.S. Tax Laws: A Review of 2016 and a Look Ahead to 2017

Jan. 13, 2017 - The year 2016 was eventful from a Canadian tax perspective, with the current Liberal government introducing its first federal budget and important judicial developments that included two decisions in tax cases by the Supreme Court of Canada. Conversely, while U.S. tax developments in 2016 were...

How Is BEPS Reflected in Canada’s Newest Treaties?

Dec. 12, 2016 - In this article published in Tax Notes International, the authors examine the extent to which Canada’s new treaties with Taiwan and Israel reflect its involvement and concern. Download this article.

Judicial and Legislative Developments Threaten Indirect Canadian Acquisitions

Oct. 10, 2016 - Originally published in Tax Notes International, this article examines new obstacles to the recovery by foreign parties of funds that were invested to indirectly acquire, through foreign companies, Canadian targets, raised by the recent decision in Univar and related proposed...

BEPS Cash Box Inconsistent with Canadian Tax Rules

Oct. 03, 2016 - Originally published in Canadian Tax Highlights, this article examines the BEPS project’s new transfer-pricing notion of “cash box,” which appears to be inconsistent both with commercial reality and with longstanding Canadian outbound international tax policy. Download this article.

Foreign Banks and Canada’s CFC System

Aug. 15, 2016 - Originally published in Tax Notes International, this article examines the Tax Court of Canada’s CIT judgment, as well as two pending companion cases, and sheds light on how the simple notion underlying controlled foreign corporation attribution rules— that CFCs’ undistributed passive...

BEPS: Canada Takes First BEPS Steps

May 24, 2016 - Originally published in Tax Notes International, this article examines provisions in Canada’s 2016 budget inspired by the OECD’s final reports on its base erosion and profit shifting project. Download this article.

2016 Federal Budget: Tax Highlights

Mar. 22, 2016 - The new Liberal government’s first budget (Budget 2016) has been the subject of anticipation and speculation, much of it apprehensive. Unusually, Budget 2016 is noteworthy for what it does not contain. Budget 2016 does not introduce changes to increase the tax rate on employee stock...

Canadian Transfer Pricing Decision in Marzen: Points of Interest

Feb. 15, 2016 - In this article from Tax Notes International, Davies partner Nathan Boidman reviews Marzen Artistic Aluminum, a Canadian transfer pricing case involving sales of Canadian products into U.S. markets. Nathan focuses on novel issues raised by the parties’ use of a Barbados...

Canadian and U.S. Tax Laws: A Review of 2015 and a Look Ahead to 2016

Jan. 20, 2016 - Each year at this time, we offer a look back at some of the more significant business and international tax developments in Canada and the United States over the past year and a look ahead to possible Canadian and U.S. tax developments in the coming year. Canadian Tax Review and...

2015 Federal Budget: Tax Highlights

Apr. 21, 2015 - As has been widely predicted, today’s federal budget (Budget 2015) delivered a handful of tax “goodies” in the lead-up to the coming election. It also includes a number of important proposed changes to the corporate tax rules. They are noteworthy, although not as...

The G20/OECD BEPS Crusade

Mar. 02, 2015 - Legal Alert, Volume 33, Number 12  Davies partner Nathan Boidman briefly examines the background to the initiative launched by the G20 and the Organisation for Economic Co-operation and Development (OECD) against base erosion and profit shifting (BEPS). Download this article.

Canadian and U.S. Tax Law: A Review of 2014 and a Look Forward to 2015

Jan. 13, 2015 - Each year at this time, we offer a look back at some of the more significant business and international tax developments in Canada and the United States over the past year and a look forward to possible Canadian and U.S. tax developments in the coming year. I. CANADIAN TAX REVIEW AND...

Transfer Pricing: Foreign Rules and Practice Outside of Europe (Foreign Income Portfolios)

Dec. 31, 2007 - (Washington: Tax Management Inc.)