ALT 5 Sigma Inc., 2024
Acted as tax counsel to ALT 5 Sigma Inc., a leading next generation blockchain financial technology provider, in its acquisition by JanOne Inc.
Tax
Business leaders conducting complex transactions want efficiency, innovative thinking and a smart, successful path to the finish line. That’s what our market-leading Canada-U.S. tax lawyers deliver.
We take on your tax challenges and develop structures that work – often pursuing strategies that break new ground. We established a Canadian landmark with the original tax-deferred conversion of a mutual fund into a REIT. And we helped devise the unique inversion structure for the merger of two global quick-service restaurant chains.
Applying our extensive experience across all major industries and sectors, we help you navigate tax environments with agility and precision. We know how to satisfy divergent interests while achieving practical results that keep all parties on course. And when tax disputes arise, we stand by your side, helping to get the matter resolved as efficiently as possible – so you can keep moving forward.
Representative Work
Professional athletes, 2024
Successfully represented Russell Martin and Joshua Donaldson, former Toronto Blue Jays players, in their tax disputes before the Tax Court of Canada against the Canada Revenue Agency. The case centered on the correct computation of their income earned in Canada under the Income Tax Act, specifically the proper allocation of employer contributions to Retirement Compensation Arrangements and their exclusion from taxable Canadian-source income.
