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Steve Suarez is a partner in the Toronto office of Borden Ladner Gervais LLP. Steve works exclusively in taxation law, with a particular focus on mining sector.  His practice is focused on mergers & acquisitions, corporate restructurings and tax dispute resolution.  Among his significant transactions in the mining sector are acting for the following clients:
Inco Limited on its proposed merger with Phelps Dodge Corporation and subsequent acquisition by Companhia Vale do Rio Doce;
Placer Dome Inc. in the unsolicited offer by Barrick Gold Corporation and resulting negotiated merger;
Eldorado Gold Corporation in its acquisition of European Goldfields Limited;
Dominion Diamond Corporation (formerly Harry Winston Diamond Corporation) in connection with its acquisition of the Ekati diamond mine from BHP Billiton Canada Inc.
Energy Fuels Inc., America’s largest conventional uranium and vanadium producer, in connection with its acquisition of Denison Mines Holding Corp. and White Canyon Uranium Limited, by way of plan of arrangement.
Walter Energy, Inc. in its acquisition of Western Coal Corp.;
Goldcorp Inc. on the sale of its interest in Terrane Metals Corp. to Thompson Creek Metals Inc.;
Pan American Silver Corp., in its acquisition of Minefinders Corporation Ltd.;
Talbot Group Investments Pty Ltd. in its acquisition and subsequent disposition to OAO Severstal of interests in PBS Coals Limited;
Discovery West Corp. on its divisive reorganization and spin-out of BlackRock Ventures Inc.; and
• the underwriters to Royal Nickel Corporation on its initial public offering of common shares, warrants and flow-through common shares;
Vietnam Resource Investments in its acquisition of Keeper Resources Inc.
• Agents (co-led by RBC Capital Markets and TD Securities Inc.) in the offering of $500 million aggregate principal amount of Senior Unsecured Debentures, Series G of Cameco Corporation.
Outside the mining sector, his significant transactions include advising The Seagram Company Ltd. in its acquisition by Vivendi, Adolph Coors Company on its merger with Molson Inc., London Stock Exchange Group PLC in its proposed merger of equals with TMX Group Inc, IBM Corporation in its acquisition of Cognos Inc., CanWest Global Communications Corp. in its acquisition of Alliance Atlantis Inc., Magna International in the going private transactions of its publicly traded subsidiaries, Tesma, Decoma and Intier Automotive and in its spin-out of MI Developments Ltd., and BCE Inc. in the formation of Bell Globemedia with The Thomson Corporation and The Woodbridge Company Limited.
Steve writes and speaks frequently on taxation matters and is active in numerous Canadian and international tax organizations, including as a Councillor of the Canadian Branch of the International Fiscal Association, the Co-Chair of the Toronto Centre Canada Revenue Agency & Tax Professionals Consultation Group, and a past Chair of the Ontario Bar Association (Taxation Section).  He is also active in the mining sector, serving on the Executive of the Management & Economics Society of the Canadian Institute of Mining, Metallurgy and Petroleum. Steve holds a J.D. from the University of Toronto Law School and an MBA from the Ivey School of Business at the University of Western Ontario, and has been acknowledged as a leading Canadian tax and mining practitioner by a number of international publications such as 2016 Lexpert/American Lawyer Guide To The Leading 500 Lawyers in Canada (the Lexpert/ALM 500): Chambers Canada 2016: Lexpert, Guide to the Leading US/Canada Cross-border Corporate Lawyers in Canada 2015: Best Lawyers of Canada 2015 Edition: Who’s Who Legal 2015 Edition: The Tax Directors Handbook 2014-The essential guide to the world’s premier tax law firms: The Legal 500 Canada (Corporate Tax), 2014 Edition: The World’s Leading Lawyers for Business (Tax) 2014: Lexpert, Leading Canadian Lawyers in Global Mining, 2013 Special Edition: Who’s Who Legal: Canada 2013: Chambers Global: Tax, and International Tax Review: World Tax 2012 and The International Who’s Who of Corporate Tax Lawyers 2012. He is called to the bars of Ontario and New York and is a solicitor in the Law Society of England & Wales.
For more information about Steve please see here.
To learn more about the Mining Group at Borden Ladner Gervais LLP, please see here.
For more tax publications from Steve, please below. For a complete list of publications and presentations by Steve, please see here.

 

TITLE CITATION PDF
The CRA demands the right to make taxpayers show it how to better audit them National Post, February 17, 2017 The CRA demands the right to make taxpayers show it how to better audit them
Flow-Through Share Financing – Critical to Canadian Mining Canadian Mining Magazine – Tax Time, Winter 2017 Flow-Through Share Financing – Critical to Canadian Mining
Employee Stock Options:  Changes Coming? Canadian Mining Magazine – Tax Time, Winter 2016 Employee Stock Options:  Changes Coming?
Canadian Thin Capitalization Developments For Foreign Currency Debt Tax Notes International – Volume 80, Number 11, December 14, 2015, p. 947 Canadian Thin Capitalization Developments for Foreign Currency Debt
Canadian Year-End Tax Planning Deadlines for 2015 Tax Notes International – Volume 80, Number 10, December 7, 2015, p. 851 Canadian Year-End Tax Planning Deadlines for 2015
Rethinking Provincial Resource Taxes Canadian Mining Magazine – Tax Time, Fall 2015 Rethinking Provincial Resource Taxes
Tax Issues on Acquiring a Canadian Business (with Kim Maguire) Tax Notes International, Volume 79, Number 9, August 31, 2015, p. 775 Tax Issues on Acquiring a Canadian Business
Corporations shouldn’t have to do the CRA’s analysis The Globe and Mail, August 31, 2015 Corporations shouldn’t have to do the CRA’s analysis
Canada Revenue Agency Declares Open Season on Taxpayer Information Tax Notes International, Volume 79, Number 2, July 13, 2015, p. 143 Canada Revenue Agency Declares Open Season on Taxpayer Information
Canada Revenue Agency Forces Taxpayer to Disclose Discussions With Accountant Tax Notes International, Volume 78, Number 6, May 11, 2015, p. 553 Canada Revenue Agency Forces Taxpayer to Disclose Discussions With Accountant
The Paragraph 88(1)(d) Bump:  Planning, Pitfalls and Developments 19th Taxation of Corporate Reorganization Conference, January 20, 21 & 22, 2015 The Paragraph 88(1)(d) Bump:  Planning, Pitfalls and Developments
Canadian Tax Planning Deadlines for 2014 Tax Noties International, Volume 76, Number 10, December 8, 2014, p. 911 Canadian Tax Planning Deadlines for 2014
Lawyer-Client Privilege Canadian Mining Magazine – Tax Time, Fall 2014 Lawyer-Client Privilege
Canada Releases Revised Back-to-Back Loan Rules Tax Notes International, Volume 76, Number 4, October 27, 2014, p. 357 Canada Releases Revised Back-to-Back Loan Rules
An Analysis of Canada’s Latest International Tax Proposals Tax Notes International, Volume 75, Number 13, September 29, 2014, p. 1131 An Analysis of Canada’s Latest International Tax Proposals
Canada’s Problematic Proposed New Loan Rules Tax Notes International, Volume 74, Number 5, May 5, 2014, p. 441 Canada’s Problematic Proposed New Loan Rules
Canada to Unilaterally Override Tax Treaties with Proposed New Anti-Treaty-Shopping Rule Tax Notes International, Volume 73, Number 9, March 3, 2014, p. 797 Canada to Unilaterally Override Tax Treaties with Proposed New Anti-Treaty-Shopping Rule
The Paragraph 88(1)(d) Bump:  Planning, Pitfalls and Developments 18th Taxation of Corporate Reorganization Conference, January 29, 30 & 31, 2014 The Paragraph 88(1)(d) Bump:  Planning, Pitfalls and Developments
Taxation Policies Key to Mining in the Far North Canadian Mining Magazing – Tax Time, 2014 Taxation Policies Key to Mining in the Far North
Canadian Tax Developments in 2013 Global Tax Weekly, Issue 57, December 12, 3013 Canadian Tax Developments in 2013
Canada’s 88(1)(d) Tax Cost Bump: A Guide for Foreign Purchasers Tax Notes International, Volume 72, Number 10, December 9, 2013, p. 957 Canada’s 88(1)(d) Tax Cost Bump:  A Guide for Foreign Purchasers
Vendor Disposition Proceeds May Exclude Certain Purchaser Assumed Obligations (with Kim Maguire) Corporate Finance, 2013 Vendor Disposition Proceeds May Exclude Certain Purchaser Assumed Obligations
Canadian tax-planning deadlines for 2013 (with Stephanie Wong) International Law Office, December 6, 2013 Canadian tax-planning deadlines for 2013
SCC Tax Judgement – Important to Mining Industry Canadian Mining Magazine, Fall 2013 SCC Tax Judgement – Important to Mining Industry
Canadian Tax Planning Deadlines for 2013 Tax Notes International, Volume 72, Number 6, November 11, 2013, p. 551 Canadian Tax Planning Deadlines for 2013
Crown Appeals Loss in Canadian Outbound Planning Case Tax Notes International, Volume 72, Number 1, October 7, 2013, p. 26 Crown Appeals Loss in Canadian Outbound Planning Case
Supreme Court Dismisses Appeal in Amalgamation Case Tax Notes International, Volume 71, Number 14, September 30, 2013, p. 1278 Supreme Court Dismisses Appeal in Amalgamation Case
Canada Releases Foreign Affiliate Dumping Amendments Tax Notes International, Volume 71, Number 10, September 2, 2013, p. 864 Canada Releases Foreign Affiliate Dumping Amendments
Cross-Border Loss Utilization 2013 International Fiscal Association Annual Conference (panel discussion), August 25-30, 2013 Cross-Border Loss Utilization
Fair for All? Quebec Raises Mining Taxes (with Kevin Bianchini) Canadian Mining Magazine, Summer 2013 Fair for All?  Quebec Raises Mining Taxes
Mining Sector Tax Measures in 2013 Federal Budget Canadian Mining Magazine, Summer 2013 Mining Sector Tax Measures in 2013 Federal Budget
Supreme Court Refuses to Hear Break Fee Appeal Tax Notes International, Volume 70, Number 6, May 6, 2013, p. 504 Supreme Court Refuses to Hear Break Fee Appeal
Tax Structuring for Canadian Investment in Latin American Mining Projects (with Michael Colborne) Rocky Minteral Law Foundation Special Institute on International Mining and Oil & Gas Law, Development and Investment, April 22-24, 2013 Tax Structuring for Canadian Investment in Latin American Mining Projects
Canadian Court Pulls Plug on GAAR Appeal Tax Notes International, Volume 70, Number 4, April 22, 2013, p. 302 Canadian Court Pulls Plug on GAAR Appeal
The Essentials of the Taxation of Mining in Nunavut Nunavut Mining Symposium 2013 The Essentials of the Taxation of Mining in Nunavut
New tax issues for foreign buyers International Law Office, March 6, 2013 New tax issues for foreign buyers
Tax Court compels disclosure in GAAR case CBA PracticeLink Bulletin, February, 2013 Tax Court compels disclsoure in GAAR case
Tax Court compels disclosure in GAAR case International Law Office, February 22, 2013 Tax Court compels disclsoure in GAAR case
Spin-outs in M&A: bridging the valuation gap (with Paul Mingay) International Law Office, February 6, 2013 Spin-outs in M&A: bridging the valuation gap
Physical Presence Determines Where Duties Are Performed, CRA Says Tax Notes International, February 4, 2013, p. 429 Physical Presence Determines Where Duties are Performed, CRA Says
Taxpayer Appeals Break Fee Case to Supreme Court Tax Notes International, February 4, 2013, p. 428-429 Taxpayer Appeals Break Fee Case to Supreme Court
Reviewing the significant tax developments of 2012 International Law Office, January 25, 2013 Reviewing the significant tax developments of 2012
Tax Court Compels Disclosure in GAAR Case Tax Notes International, Volume 69, Number 3, January 21, 2013, p. 238 Tax Court Compels Disclosure in GAAR Case
2012:  The Year in Review (Canada) (with Stephanie Wong) Tax Notes International, Volume 68, Number 13, December 24, 2012, p. 1191 2012:  The Year in Review (Canada)
New Foreign Affiliate ‘Dumping’ Rules Constitute Major Canadian Tax Policy Change Tax Notes International, Volume 68, Number 12, December 17, 2012, p. 1145 New Foreign Affiliate Dumping Rules Constitute Major Canadian Tax Policy Change
Federal Court of Appeal Confirms Tax Treatment of Break Fees Tax Notes International, Volume 68, Number 10, December 3, 2012, p. 890 Federal Court of Appeal Confirms Tax Treatment of Break Fees
Canadian Year-End Tax Planning Deadlines for 2012 (with Stephanie Wong) Tax Notes International, Volume 68, Number 7, November 19, 2012, p. 747 Canadian Year-End Tax Planning Deadlines for 2012
CRA Reverses Position on Cross-Border Stock Options Tax Notes International, Volume 68, Number 9, November 26, 2012, p. 801 CRA Reverses Position on Cross-Border Stock Options
Canada Revenue Agency’s Foreign Spinoff Guidance Tax Notes International, Volume 68, Number 1, October 1, 2012, p. 111 Canada Revenue Agency’s Foreign Spinoff Guiance
October 15, 2012 Draft Legislation Targets Foreign-owned Canadian Companies Corporate Tax Planning Series:  Corporate Finance, Vol. 18, No. 2 October 15, 2012 Draft Legislation Targets Foreign-owned Canadian Companies
Foreign multinationals: beware new Canadian ‘debt dumping’ proposals International Bar Association, Legal Division, Taxes Newsletter, September 2012 Foreign multinationals: beware new Canadian ‘debt dumping’ proposals
Foreign Exchange Tax Treatment:  Planning for International Transactions in Volatile Currency Markets Taxation of Corporate Finance and Financial Structures, June 5, 2012 Foreign Exchange Tax Treatment:  Planning for International Transactions in Volatile Currency Markets
Eye on Business: Federal government adjusts mining tax credits CIM Magazine, June/July, 2012 Eye on Business:  Federal government adjusts mining tax credits
Trends in Canadian Tax:  Tightening the Net (with Patrick Lindsay and Salvatore Mirandola) The Canadian Business Journal, June 12, 2012 Trends in Canadian Tax:  Tightening the Net
How to Consolidate Tax Losses of a Related Corporation The Canadian Business Journal, June 12, 2012 How to Consolidate Tax Losses of a Related Corporation
Supreme Court to Hear Appeal in Amalgamation Case Tax Notes International, Volume 66, Number 13, June 25, 2012, p. 20 Supreme Court to Hear Appeal in Amalgamation Case
Supreme Court Grants Taxpayer Leave To Appeal in Daishowa Tax Notes International, Volume 66, Number 11, June 11, 2012, p. 1006 Supreme Court Grants Taxpayer Leave to Appeal in Daishowa
Supreme Court Will Not Hear Appeal In Stock Options Case Tax Notes International, Volume 66, Number 10, June 4, 2012, p. 911 Supreme Court Will Not Hear Appeal in Stock Options Case
Caselaw Update, 2nd Understanding Natural Resources Taxation Federated Press Conference, May 23, 2012 2nd Understanding Natural Resources Taxation
Inbound Financing and Investments, 2012 Mining Taxation Update Acumen Information Conference, May 10, 2012 Inbound Financing and Investments, 2012 Mining Taxation Update
News Analysis:  Supreme Court Holds Off on Daishowa Tax Notes International, Volume 66, Number 6, May 7, 2012, p. 514 News Analysis:  Supreme Court Holds off on Daishows
Canadian 2012 Federal Budget:  Tightening the Screws Tax Notes International, Volume 66, Number 3, April 16, 2012, p. 247 Canadian 2012 Federal Budget:  Tightening the Screws
Canada’s Section 116 System for Nonresident Vendors of Taxable Canadian Property (with Marie-Eve Gosselin) Tax Notes International, Volume 66, Number 2, April 9, 2012, p. 175 Canada’s Section 116 System for Nonresident Vendors of Taxable Canadian Property
Using Tax Losses Within a Canadian Group of Companies Tax Notes International, Volume 66, Number 1, April 2, 2012, p. 59 Using Tax Losses Within a Canadian Group of Companies
Timber! Consequences of Assuming Reforestation Obligations (with Michael Colborne) Canadian Tax Journal, Volume 60, Number 1, 2012 Timber! Consequences of Assuming Reforestation Obligations
Canada Extends Transition Period For Treaty-Reduced Nonresident Withholding Tax Notes International, Volume 65, Number 9, February 27, 2012, p. 687 Canada Extends Transition Period For Treaty-Reduced Nonresident Withholding
Supreme Court Again Denies Review In Antle Tax Notes International, Volume 65, Number 7, February 13, 2012, p. 500 Supreme Court Again Denies Review In Antle
The 88(1)(d) Bump: Planning, Pitfalls & Developments 16th Taxation of Corporate Reorganizations Conference, January 12, 2012 (Federated Press) The 88(1)(d) Bump: Planning, Pitfalls & Developments
Important Deadlines Nearing for Canadian Taxpayers Worldwide Tax Daily, Tax Analysts, December 20, 2011 Important Deadlines Nearing for Canadian Taxpayers
2011: The Year in Review (Canada) Tax Notes International, Volume 64, Number 12, December 19, 2011, p. 872 2011: The Year in Review (Canada)
Canadian Appellate Court Issues Split Decision on Transferred Liabilities Tax Notes International, Volume 64, Number 2, October 10, 2011, p. 108 Canadian Appellate Court Issues Split Decision on Transferred Liabilities
Foreign Exchange Tax Treatment: Planning for International Transactions in Volatile Currency Markets Taxation of Corporate Finance and Financial Structures, June 21, 2011 (Acumen Information Services) Foreign Exchange Tax Treatment: Planning for International Transactions in Volatile Currency Markets
2011 Federal Budget Mostly Unchanged Tax Notes International, June 20, 2011, Volume 62, Number 12, p. 940 2011 Federal Budget Mostly Unchanged
Voters Reelect Conservative Government Tax Notes International, Volume 62, Number 6, May 9, 2011, p. 463 Voters Reelect Conservative Government
Tax Measures in Canadian Budget May Have to Wait Tax Notes International, Volume 62, Number 2, April 11, 2011, p. 80 Tax Measurers in Canadian Budget May Have to Wait
Canadian Taxation of Mining Tax Notes International, Volume 60, Number 11, December 13, 2010, p. 867 Canadian Taxation of Mining
Tax Executives Urge Group Loss Relief for Canada Tax Notes International, Volume 60, Number 4, October 25, 2010, p. 231 Tax Executives Urge Group Loss Relief for Canada.pdf
Draft Legislation Would Fix Nonresident Tax Trap Tax Notes International, Volume 59, Number 13, September 27, 2010, p. 1009 Draft Legislation Would Fix Nonresident Tax Trap.pdf
Canada Sets Policy on Accessing Accountant’s Working Papers Tax Notes International, Volume 58, Number 12, June 21, 2010, p. 935 Canada Sets Policy on Accessing Accountants’ Working Papers.pdf
Canada Will Not Appeal Ruling on LLC’s Treaty Rights Tax Notes International, Volume 58, Number 7, May 17, 2010, p. 412 Canada Will Not Appeal Ruling on LLC’s Treaty Rights.pdf
Canadian LLC Ruling Overturns Long-Standing Policy Tax Notes International, Volume 58, Number 3, April 19, 2010, p. 199 Canadian LLC Ruling Overturns Long-Standing Policy.pdf
Canada’s 2010 Budget Heavy with Major Tax Initiatives Tax Notes International, Volume 57, Number 12, March 22, 2010, p. 1021 Canada’s 2010 Budget Heavy with Major Tax Initiatives.pdf
The Taxation of Mobile Activities Bulletin for International Taxation, Volume 61, No. 1, January 2010, pp. 45-50 The Taxation of Mobile Activities
Thoughts on the New LOB Clause in the Canada-U.S. Treaty Tax Notes International, Volume 56, Number 1, October 5, 2009, p. 39 Thoughts on the New LOB Clause in the Canada-US Treaty.pdf
Withholding Decision Creates Windfall for Revenue Canada (with David Gaskell) Tax Notes International, Volume 55, Number 8, August 24, 2009, p. 600 Withholding Decision Creates Windfall for Revenue Canada.pdf
Canada Updates Policy on Assessing Working Papers Tax Notes International, Volume 55, Number 3, July 20, 2009, p. 172 Canada Updates Policy on Assessing Working Papers.pdf
Multinational Groups with Canadian Members in Hard Times (with Susan Wooles) Tax Notes International, Volume 55, Number 3, July 20, 2009, p. 225 Multinational Groups with Canadian members in Hard Times.pdf
Further Clarification on Revised Regime for Non-resident Vendors Tax Notes International, Volume 55, Number 1, July 6, 2009, p. 21 Further Clarification on Revised Regime.pdf
The OECD Discussion Draft on Transfer Pricing Aspects of Business Restructurings – Canadian Considerations(with Richard Tremblay) Tax Management International Journal, Volume 28, Number 2, February 13, 2009, p. 98 The OECD Discussion.PDF
Canadian Budget Delivers Outbound Tax Relief Tax Notes International, Volume 53, Number 5, February 2, 2009, p. 383 Canadian Budget Delivers Outbound Tax Relief.pdf
Canada’s Revised Section 116 Regime for Non-resident Vendors (with David Gaskell) Tax Notes International, Volume 53, Number 4, January 26, 2009, p. 321 Canada’s Revised Section 116 Regime for Non-resident Vendors.pdf
Canadian Taxation of Foreign Exchange Gains and Losses (with Byron Beswick) Tax Notes International, Volume 53, Number 2, January 12, 2009, p. 157 Canadian Taxation of Foreign Exchange Gains and Losses.pdf
Ten Essential Elements of Canada’s Tax System(with Susan Wooles) Tax Notes International, Volume 51, Number 10, September 8, 2008, p. 825 Ten Essential Elements of Canada’s Tax System.pdf
Canada’s Taxation of Stock Option Benefits:  Could the SDL Remission Order Benefit Others? Tax Notes International, Volume 49, Number 9, March 3, 2008, p. 777 Canada’s Taxation of Stock Option Benefits.pdf
Canada’s 2008 Budget is Light on Business Tax Measures Worldwide Tax Daily, Tax Analysts, February 28, 2008 Canada’s 2008 Budget is Light on Business Tax Measures.pdf
Using Exchangeable Shares in Inbound Canadian Transactions (with Pooja Samtani) Tax Notes International, Volume 48, Number 13, December 24, 2007, p. 1281 Using Exchangeable Shares in Inbound Canadian Transactions.pdf
New 88(1) Comfort Letter Address Bump Anomaly Canadian Current Tax, Volume 18, Number 1, October 2007, p. 1-5 New 88(1) Comfort Letter Addresses Bump Anomaly.PDF
Canada Makes Major Revisions to Interest Proposals Tax Notes International, Volume 46, Number 8, May 21, 2007, p. 1-5 Canada Makes Major Revisions to Interest Proposals.pdf
Canadian Budget has Cross-Border Focus Tax Notes International, Volume 45, Number 12, March 26, 2007, p. 1166 Canadian Budget Has Cross-Border Focus.pdf
Tax Aspects of Debt Settlement:  A Primer Insolvency News, February 2007, p. 15 Tax Aspects of Debt Settlement A Primer.pdf
Canada’s Tax Cost Step-Up:  What Foreign Purchasers Should Know Tax Notes International, Volume 44, Number 10, December 4, 2006, p. 779 Canada’s Tax Cost Step-Up.pdf
Tax Planning with Losses in Canada Tax Notes International, Volume 39, Number 5, August 1, 2005, p. 451 Tax Planning with Losses in Canada.pdf
Finance Minister Presents 2005 Budget Tax Notes International, Volume 37, Number 10, March 7, 2005, p. 869 Finance Minister Presents 2005 Budget.pdf
The Capital Property Dividend Stop-Loss Rules (précis only) Canadian Tax Journal, Volume 53, Number 1, 2005, p. 269-91 The Capital Property Dividend Stop-Loss Rules.pdf
Public Company Non-Butterfly Spinouts (précis only)(with Firoz Ahmed) Canadian Tax Foundation, 55thAnnual Tax Conference, September 23, 2003, 32:1-63 Public Company Non-Butterfly Spinouts.pdf