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Taxation Law

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The Davis LLP Taxation Group offers taxation advice through lawyers in all of our offices. Our experienced lawyers are actively involved in providing legal services in all aspects of federal and provincial taxation.

We have extensive experience in corporate tax planning, mergers and acquisitions, corporate finance, investments by Canadians in other jurisdictions, non-resident investment in Canada and tax planning for owner-managers. We also have significant expertise in all aspects of tax litigation, including dispute resolution with Canada Revenue Agency and representing clients in cases before provincial courts, the Tax Court of Canada, the Federal Court of Appeal and the Supreme Court of Canada.

We have developed particular expertise in the following specific areas of taxation:

  • Tax planning for private and public infrastructure projects, including public-private partnerships
  • Tax planning for inbound and outbound cross-border Canadian investments
  • Tax planning for Canadian and foreign-based families, including the use of trusts and all aspects of tax planning for estates
  • Tax-efficient corporate financings and securitization, syndicated tax shelters, lease transactions
  • Tax-effective structuring of complex corporate reorganizations, debt restructuring, acquisitions and divestitures, joint ventures and partnerships
  • Taxation of executives and employee compensation
  • Taxation of Aboriginal peoples, including the taxation of First Nations and the structuring of joint ventures with First Nations
  • Tax planning for technology companies
  • Provincial taxes, such as sales tax, corporation capital tax and property transfer tax
  • Tax effective structuring and re-structuring of franchise systems
  • Federal commodity taxes, such as customs duties and goods and services tax
  • Dispute resolution with Canada Revenue Agency and litigation of tax cases at all court levels

Representative Matters

Our Group has provided advice and representation on a variety of matters, including:

  • The successful amendment to the Canadian Income Tax Act for a client who emigrated from Canada and faced a $10 million tax bill.
  • The tax efficient structuring and corporate implementation to facilitate the acquisition by Newport Fund and Newport Partners Holdings LP of owner-manager business operations in the fund's rapidly expanding investment activities.
  • A long-term concession agreement for the design, construction, partial financing, operation and maintenance for the $1.9 billion 19.5 km rapid transit RAV/Canada Line in Vancouver, B.C.
  • A concession agreement and a $157 million financing for the new Okanagan Lake Bridge in B.C.
  • The $1.2 billion (+ working capital) acquisition of Weyerhaeuser's B.C. timber assets by Brascan Corporation (now known as Brookfield Asset Management). The transaction included freehold timberlands, sawmills, remanufacturing facilities and Crown harvest rights.
  • The $70 million acquisition of MDSI Mobile Data Solutions Inc. by Vista Equity Partners. The acquisition was through an investment vehicle managed by Vista which acquired all of the outstanding shares of MDSI for US$8.00 cash per share.
  • The $130 million design-build-finance-operate Kicking Horse Canyon Phase 2 public-private partnership (P3) project. Davis represented Bilfinger Berger BOT Inc. and Trans-Park Highway General Partnership with respect to the 25 year concession agreement with the Province of British Columbia and a corresponding financing package with CIT Group Securities (Canada) Inc.

Recognition and Activities

We are committed to remaining at the forefront of taxation law. This is reflected by our numerous writings on specialized taxation subjects for a variety of publications, as well as our frequent presentations at local and national conferences on taxation matters. Our lawyers are recognized as possessing the highest levels of tax expertise.


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