Tax

Our Tax Group advises a variety of clients with tax issues, which range from basic and complex.  

We provide creative, tax efficient and cost effective answers to tax problems and challenges. We collaborate with our clients’ internal tax and accounting departments, external accounting firms, financial advisors and investment bankers to address all of our clients’ tax needs. In doing so, we develop and implement our own tax planning as well as implement tax planning of other advisors. In addition, our Tax Group represents clients in tax dispute matters involving the Canada Revenue Agency and provincial tax authorities.

Our Tax Group works closely with all the practice groups in our firm to address overall tax planning as well as tax issues that arise in both corporate transactions and personal matters. Our Tax Group draws on a wealth of experience representing both private and public corporations, limited partnerships, financial institutions, private equity firms, securities dealers and advisers, and investment funds in both domestic and cross-border transactions.

Mergers and Acquisitions

When purchasing or selling a business or assets, the tax consequences will often dictate the structure of the deal. Our Tax Group works closely with our Business Law Group to advise and implement a tax efficient structure on the purchase or sale of a business or assets.  Some of our services include advising on, structuring and implementing:

  • Share transactions
  • Asset transactions
  • Hybrid sale transactions
  • Pre-sale tax planning
  • Pre-acquisition tax planning
  • Tax due diligence

Corporate Reorganizations

We have the depth of experience and knowledge to ensure that our clients’ corporate reorganizations will meet both their business needs while being carried out in the most tax efficient manner. 

  • Butterfly transactions
  • Loss utilization planning
  • Amalgamations
  • Wind-ups
  • Incorporations
  • Tax-deferred rollover planning
  • Tax minimization amongst related groups and shareholders

Corporate Finance and Investment Funds

Our Tax Group works closely with the Business Law Group to structure investment funds and other private equity investments. We assist clients with structuring and implementing transactions, including private placements and public offerings of securities, and capital pool company (CPC) transactions.

International Tax Planning

We regularly advise clients on the tax consequences of cross-border transactions, including acquisitions, sales, financings, partnerships, licensing arrangements, joint ventures and the structuring and restructuring of international groups. Our Tax Group advises international clients on doing business in Canada and Canadian clients expanding their businesses abroad. 

We also advise individuals on international tax planning. Our Tax Group works closely with international advisors to ensure integration between the applicable jurisdictions.  We have significant experience working with US advisors on US income and estate tax matters.

  • Inbound and outbound investments and transactions
  • Cross-border planning for businesses
  • Transfer pricing
  • Dual citizens
  • Immigrating to Canada
  • Emigrating from Canada
  • Foreign trusts

Owner Manager/Estate Planning

We advise on and implement tax-effective solutions for individuals and families including owners of privately held businesses, professionals and other high-net-worth individuals with respect to their personal and corporate tax planning needs. In doing so we work with our colleagues in our Wills, Trusts & Estates, Family Law, Real Estate and Charities and Not-for-Profit groups.

  • Estate freezes
  • Trusts
  • Succession planning
  • Tax-structured wills
  • Post-mortem planning
  • Tax minimization and remuneration planning
  • Shareholder agreements

Commodity Tax

We help clients in all areas of federal and provincial commodity tax, whether it be in the supply, import or acquisition of goods or services. Our Tax Group provides skilled legal advice with respect to sales and other indirect taxes on the purchase and sale of a business, audits and disputes as well as cross-border transactions.

Dispute Resolution

Our Tax Group provides thoughtful and experienced advocacy on behalf of clients in both federal and provincial tax disputes. We represent corporate and individual clients at all stages of the dispute resolution process, from audit to objections to appeals. We also have considerable experience in drafting and negotiating Voluntary Disclosures.

  • Audits
  • Notices of objection
  • Tax litigation
  • Voluntary disclosures
  • Collection matters
  • Taxpayer relief applications
Date Title Related Lawyers Type

July 2017

Sweeping Proposed Tax Changes to Private Corporations

Torkin Manes LegalPoint

Kay Leung

Article

March 2016

Federal Budget 2016 - Did it Live Up to the Hype?

Torkin Manes LegalPoint

Wesley Isaacs
Marc Weisman

Newsletter

February 2016

Giving Undertaking or Deficiency Agreements to Lenders/Creditors: Mere Words or Are they Much More?

Torkin Manes LegalPoint

Barry A. Cohen, QC

Newsletter

December 2015

The Unexpected Creditor: Why the Right to Redeem or Retract Shares Matters to Lenders

Torkin Manes LegalPoint

Barry A. Cohen, QC
Marc Weisman

Newsletter

October 2015

Why Do I Need a Will?

Torkin Manes LegalSource

Guide

February 2015

The Application of GST/HST to Children's Camps Operated by Charities and Non-Profits

Torkin Manes LegalPoint

Newsletter

December 2014

Tax Considerations for Different Business Structures

Corporate Tax: An Introduction (YLD), Ontario Bar Association, December 2014

Presentation

November 2014

The New Kid in Class

M & A Trends for Private Companies and their Shareholders, Torkin Manes Annual Business Law Seminar

Presentation

June 2014

Avoidance Rules and Attacks on Trusts and Foundations

Foundations and Trusts in International Estate Planning, International Young Lawyers Association and International Bar Association, Berlin, Germany (co-presenter)

Presentation

April 2014

Tax and Other Relocation Considerations - Business Travel and Short-Term Mobility

International Legal Trends, International Young Lawyers Association and International Association of Lawyers, Toronto (co-presenter)

Presentation

More Publications

Marc Weisman

Practice Group Lead

Tel: 416 777 5455  Fax: 1 888 812 2565
Email: mweisman@torkinmanes.com

Wesley Isaacs

Tel: 416 360 4735  Fax: 1 844 842 9183
Email: wisaacs@torkinmanes.com

Kay Leung

Tel: 416 777 5428  Fax: 1 888 812 2561
Email: kleung@torkinmanes.com

Practice Group Lead(s)

Marc Weisman 416 777 5455 mweisman@torkinmanes.com

Practice Group Lawyers

Wesley Isaacs 416 360 4735 wisaacs@torkinmanes.com
Kay Leung 416 777 5428 kleung@torkinmanes.com
Back to all Services