Michael's experience involves a number of different areas, including:
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cross border (both inbound and outbound) investment
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resource taxation
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federal and provincial tax credit programs (including SRED and Digital Media Tax Credit Programs)
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public company transactions (including plans of arrangement, amalgamations, going-private transactions and corporate "spin-outs")
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exchangeable securities transactions
In 2011 and 2012 he has provided tax advice on the following transactions:
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a $172,500,000 offering of convertible debentures
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over $35,000,000 in offerings of flow-through shares
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the acquisition of a public company valued at $700,000,000 by way of a Plan of Arrangement
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an acquisition of real property by a Real Estate Investment Trust by way of the issuance of convertible partnership units
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the reorganization of major Canadian infrastructure assets by a UK-based Limited Partnership
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the acquisition of Canadian-based resource properties by a Chinese consortium
In addition to transaction work, Michael also provides tax advice on a variety of ongoing matters. These include:
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Ensuring that private company securities qualify as eligible investment for Registered Retirement Savings Plans and Tax-Free Savings Accounts
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Resolving taxpayer disputes with the Canada Revenue Agency
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Structuring tax-orientated investment entities including Mutual Funds Trusts and Mortgage Investment Corporations
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Special tax programs for video game developers and other entertainment orientated industries
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Tax-effective structuring of stock options and other incentive plans
Michael also maintains an active ongoing commercial law practice focusing on private company matters. Michael's experience in this area includes:
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the purchase and sale of a business (both asset and share-based transactions)
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drafting shareholder agreements
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corporate reorganizations
