Mining Tax Canada | Publications & Presentations

“Inbound Financing and Investments”, 2010 Mining Taxation Update, Acumen Information, May 10, 2012
“News Analysis: Supreme Court Holds off on Daishowa”, Tax Notes International, Vol. 66, No. 6, May 7, 2012, p. 514
“Canadian 2012 Federal Budget: Tightening the Screws”, Tax Notes International, Vol. 66, No. 3, April 16, 2012, p. 247
“Canada’s Section 116 System for Nonresident Vendors Of Taxable Canadian Property” (with Marie Eve-Gosselin), Tax Notes International, April 9, 2012
“Using Tax Losses Within a Canadian Group of Companies”, Tax Notes International, Vol. 66, No. 1, April 2, 2012, p. 59
“Timber! Consequences of Assuming Reforestation Obligations” (with Michael Colborne), Canadian Tax Journal, Vol. 60, No. 1, 2012
“The Paragraph 88(1)(d) Bump: Planning, Pitfalls and Developments”, 16th Taxation of Corporate Reorganizations Conference, Federated Press, January 12, 2012
“2011 Review, Canada”, Tax Notes International, Vol. 64, No. 12, p. 872
“Important Deadlines Nearing for Canadian Taxpayers”, Worldwide Tax Daily, Tax Analysts, December 20, 2011
“Canadian Appellate Court Issues Split Decision on Transferred Liabilities”, Tax Notes International, Vol. 64, No. 2, October 10, 2011, p. 108
“Foreign Exchange Tax Treatment: Planning for International Transactions in Volatile Currency Markets”, Taxation of Corporate Finance and Financial Structures
“2011 Federal Budget Mostly Unchanged”, Tax Notes International, Vol. 62, No. 12, June 20, 1011
“Tax Measures in Canadian Budget May Have to Wait”, Tax Notes International, Vol. 62, No. 2, April 11, 2011
“Flow-Through Shares – An Important Financing Tool for Canadian Resource Companies”, Osler Mining Review, December 2010
“Canadian Taxation of Mining”, Tax Notes International, Special Reports, December 13, 2010
“Tax Executives Urge Group Loss Relief for Canada”, Tax Notes International, Vol. 60, No. 4, October 25, 2010
“Draft Legislation Would Fix Nonresident Tax Trap”, Tax Notes International, Vol. 59, No. 13, September 27, 2010
“Ethics and the Codification of Economic Substance”, American Bar Association (Tax Section), Panel Presentation, Fall Meeting, September 24, 2010
“Canada Sets Policy on Accessing Accountant’s Working Papers”, Tax Notes International, Tax Analysts, Vol. 58, No. 12, June 21, 2010
“Demystifying the 88(1)(d) Bump”, presentation at Canada Revenue Agency Large File Auditors, June 8, 2010
“Canada Will Not Appeal Ruling on LLC’s Treaty Rights”, Tax Notes International, Tax Analysts, Vol. 58, No. 7, May 17, 2010
“Canadian LLC Ruling Overturns Long-Standing Policy”, Tax Notes International, Tax Analysts, Vol. 58, No. 3, April 19, 2010
“Canada’s 2010 Budget Heavy with Major Tax Initiatives”, Tax Notes International, Tax Analysts, Vol. 57, No. 12, March 22, 2010
“Canada’s Loss Transfer System”, presentation at BDO Dunwoody National Tax Specialist Conference, January 11, 2010
“The Taxation of Mobile Activities”, Bulletin for International Taxation, Vol. 64, No. 1, January 2010
“Canada’s Loss Transfer System”, (with Wayne Adams, Canada Revenue Agency), presentation to the Toronto Centre CRA & Tax Professionals Group, October 27, 2009
“Thoughts on the New LOB Clause in the Canada-U.S. Treaty”, Tax Notes International, Tax Analysts, Vol. 56, No. 1, October 5, 2009
“Race to the Bottom: Taxation of Mobile Activities”, Panel Chair, 63^rd Congress of the International Fiscal Association, September 2, 2009 (Vancouver)
“News Analysis: Withholding Decision Creates Windfall for Revenue Agency”, (with David Gaskell), Tax Notes International, Tax Analysts, Vol. 55, No. 8, August 24, 2009
“Multinational Groups with Canadian Members in Hard Times”, (with Susan Wooles), Tax Notes International, Tax Analysts, Vol. 55, No. 3, July 20, 2009
“Canada Updates Policy on Accessing working Papers”, Tax Notes International, Tax Analysts, Vol. 55, No. 3, July 20, 2009
“Canada Revenue Agency Nearing Final Position on Access to working Papers”, Tax Notes International, Tax Analysts, July 10, 2009
“News Analysis: Further Clarification on Revised Regime for Nonresident Vendors”, Tax Notes International, Tax Analysts, Vol. 55, No. 1, July 6, 2009
“CRA Perspectives on the New Section 116 Rules” (with Claude Charron, Canada Revenue Agency), presentation to the Toronto Centre CRA & Tax Professionals Group, February 11, 2009
“The OECD Discussion Draft on Transfer Pricing Aspects of Business Restructurings, Canadian Considerations” (with Richard Tremblay), Tax Management International Journal, Vol. 38, No. 2, February 13, 2009
“Canadian Budget Delivers Outbound Tax Relief”, Tax Notes International, Tax Analysts, Vol. 53, No. 5, February 2, 2009
“Canada’s Revised Section 116 Regime for Nonresident Vendors” (with David Gaskell), Tax Notes International, Tax Analysts, Vol. 53, No. 4, January 26, 2009
“Canadian Taxation of Foreign Exchange Gains and Losses” (with Byron Beswick), Tax Notes International, Tax Analysts, Vol. 53, No. 2, January 12, 2009
“Deadline Extended for Electing Foreign Currency Reporting”, Tax Notes International, Tax Analysts, Vol. 52, No. 6, November 10, 2008
“Acquisitions – A Framework” (with Pooja Samtani), presentation to Canada Revenue Agency Large File Auditors, September 23, 2008
“Ten Essential Elements of Canada’s Tax System” (with Susan Wooles), Tax Notes International, Tax Analysts, Vol. 51, No. 10, September 2, 2008
“Government Proposes Extending Foreign Affiliate Election Deadline” (with Drew Morier), Tax Notes International, Tax Analysts, Vol. 51, No. 2, July 14, 2008
“Foreign Affiliate Election Deadline Approaching” (with Drew Morier), Tax Notes International, Tax Analysts, Vol. 50, No. 9, June 2, 2008
“Canada’s Taxation of Stock Option Benefits: Could the SDL Remission Order Benefit Others”, Tax Notes International, Tax Analysts, Vol. 49, No. 9, March 3, 2008
“Canada’s 2008 Budget is Light on Business Tax Measures”, Tax Analysts Worldwide Tax Daily, February 28, 2008
“Using Exchangeable Shares in Inbound Canadian Transactions” (with Pooja Samtani), Tax Notes International, Tax Analysts, Vol. 48, No. 13, December 24, 2007
“New 88(1) Comfort Letter addresses Bump Anomaly”, Practice and Planning Tips, Canadian Current Tax, Vol. 18, No. 1, October 2007
“Canada Makes Major Revisions to Interest Proposal”, Tax Notes International, Tax Analysts, Vol. 46, No. 8, May 21, 2007
“Revisions Expected on Interest Deductibility Proposal”, Tax Notes International, Tax Analysts, Vol. 46, No. 7, May 14, 2007
“Interest Deductibility Proposal Troubles Tax Community”, Tax Notes International, Tax Analysts, Vol. 46, No. 5, April 30, 2007
“Canadian Budget Has Cross-Border Focus”, Tax Notes International, Tax Analysts, Vol. 45, No. 12, March 26, 2007
“Canada’s Tax Cost Step-Up: What Foreign Purchasers Should Know”, Tax Notes International, Tax Special Reports, Vol. 44, No. 10, December 4, 2006
“Canadian Finance Minister Hints at Further Tax Cuts”, Worldwide Tax Daily, Tax Analysts, 218-2, November 13, 2006
“Canadian Finance Minister to Introduce New Economic Agenda”, Worldwide Tax Daily, Tax Analysts, 214-2, November 6, 2006
“Canada Issues Revised Dividend Tax Credit Legislation” (with Manjit Singh), Tax Notes International, Tax Analysts, Vol. 44, No. 5, October 30, 2006
“Government Moves to Enact Remaining 2006 Budget Measures”, Tax Notes International, Tax Analysts, Vol. 43, No. 11, September 11, 2006
“Canadian Budget Puts Focus on Tax Relief”, Tax Notes International, Tax Analysts, Vol. 42, No. 6, May 8, 2006
“New Government’s Campaign Platform Suggests Tax Plans”, Tax Notes International, Tax Analysts, Vol. 41, No. 4, January 30, 2006
“Tax Planning With Losses in Canada”, Tax Notes International, Tax Analysts, Vol. 39, No. 5, August 1, 2005
“Canada’s 2005 Budget Survives Crucial Vote”, Worldwide Tax Daily, Tax Analysts, 98-1, May 23, 2005
“Political Scandal Threatens Liberal Government, Budget”, Tax Notes International, Tax Analysts, Vol. 38, No. 6, May 9, 2005
“Finance Minister Presents 2005 Federal Budget”, Tax Notes International, Tax Analysts, Vol. 37, No. 10, March 7, 2005
“Budget Briefing 2005” (with Judith Harris, et al), Osler Update, February 23, 2005
“The Capital Property Dividend Stop-Loss Rules”, Canadian Tax Journal, Vol. 53, No. 1, 2005
“The Initiatives in the 2004 Canadian Federal Budget” (with Matthew Peters), Tax Planning International Review, May 2004
“Canadian Government Proposes Significant Revision of Tax Rules” (with Patrick Marley), Tax Notes International, Tax Analysts, Vol. 34, No. 1, April 5, 2004
“Budget Briefing 2004” (with Judith Harris, et al), Osler Update, March 23, 2004
“Corporate Distributions”, guest lecture, LL.M. (Taxation) programme, Osgoode Hall law School, January 29, 2004
“Public Company Non-Butterfly Spin-Outs”, Canadian Tax Foundation, Young Practitioners Group Meeting, November 4, 2003
“Public Company Non-Butterfly Spin-Outs” (with Firoz Ahmed), Canadian Tax Foundation, 55th Annual Tax Conference, September 23, 2003 (for paper, see 2003 Conference Report, 2003 CR:32:1-63)
“Comparison of Canadian/US Reorganizations” (with Doug McFadyen), Canadian Tax Foundation, February 5, 2003
“Taxable Canadian Property Redefined”, Canadian Tax Highlights, Vol. 11, No. 2, February 2003
“Recent Tax Developments – 2002”, Ontario Bar Association, August 2002
“New Revisions to Draft ‘Foreign Investment Entity’ Rules” (with Patrick Marley), International Tax Newsletter (CCH), Report #4, September 2001
“Introduction to Canadian Taxation of Information Technology Transactions”, Information and Technology and Cyberspace Law: Osgoode Hall Law School, May 9-12, 2001
“Recent Developments in Electronic Commerce”, Second Annual – What’s New In Taxing Electronic Commerce; Strategy Institute Conference, March 6, 2001
“Introduction to Canadian Taxation of Electric Commerce”, CGA Tax Interest Group (Toronto Region), January 2001
“Tax and E-Commerce: Latest Developments, Newest Strategies”, Osler, Hoskin & Harcourt LLP Client Seminar, November 9, 2000
“Introduction to Canadian Taxation of Electric Commerce, E-Commerce Advances”, Osgoode Hall Law School, November 2, 2000
“Ontario 2000 Budget – Taxation of R&D Employee Stock Options”, Information & Technology Law, Vol. 4, No. 3, November 2000
“Ontario 2000 Budget – Taxation of R&D Employee Stock Options”, Tax Law Update: CBAO, Vol. 11, No. 1, October 2000
“Taxation of Electronics Commerce”, guest lecture, LL.B. programme, Osgoode Hall Law School, September 28, 2000
“Income Taxes and E-Commerce”, ACCA Focus, Vol. 6, No. 3, September 2000
“What’s At Stake? Income Taxes and E-Commerce”, The Bottom Line, Vol. 16, No. 9, August 2000
“E-Commerce A Canadian Perspective”, Journal of International Tax, Vol. 11, No. 8, August 2000
“Taxation of Employee Stock Options & The 2000 Federal and Ontario Budgets”, Osler Update, July 10, 2000
“Income Taxes and E-Commerce”, Osler Outlook, Summer 2000
“Delaware Changes the Rules for Limited Partnerships”, Osler, Hoskin & Harcourt LLP Client Seminar, June 8, 2000
“E-Commerce Taxation: The OECD Proposal”, Information and Technology Law, Vol. 4, No. 2, June 2000
“Introduction to Canadian Taxation of Information Technology Transactions”, Information Technology and Cyberspace Law Osgoode Hall Law School, May 10-13, 2000
“E-Commerce and Income Tax: International Policy Developments”, Internet and E-Commerce Law in Canada, Vol. 1, No. 3, May 2000
“Commercializing Information Technology – Common Hurdles, Roadblocks, Pitfalls and Traps – How to Avoid Tripping Up, The Art and Science of Financing High Techs, The Canadian Institute, April 12-13, 2000
“Canadian Taxation of Electronic Commerce: An Introduction, E-Commerce Law: Understanding the Legal Implications of Conducting Business in Cyberspace, Institute for International Research, April 10-12, 2000
“The Taxation of Electronic Commerce: Are You Prepared?”, Canadian Corporate Counsel, Vol. 9, No. 3, December 1999
“Introduction to Canadian Taxation of Electronic Commerce, E-Commerce in the New Millennium, Osgoode Hall Law School, October 13-14, 1999
“The Taxation of Electronic Commerce”, 3 Information & Technology law, No. 3, October 1999
“Tax Liabilities in Electronic Commerce, Managing Online Risk and Liability”, Federated Press, August 31 and September 1, 1999
“Technology-Related Initiatives in the 1999 Ontario Budget” (with Bernard Morris), 3 Information and Technology Law, No. 2, July 1999
“The Taxation of Electronic Commerce: Are You Prepared?”, Bennett Jones Electronic Commerce Comment, Summer 1999
“Introduction to Canadian Taxation of Information Technology Transaction”, Information Technology and Cyberspace Law, Osgoode Hall Law School, May 26-29, 1999
“Y2K Tax Issues for Investment Advisors”, Mandatory Year 2000 Investment Industry Protection Strategies, Strategy Institute, January 20, 1999
“Canada Proposes Tax Benefit to Address Year 2000 Computer Problem” (with Steven Sieker), 17 Tax Notes International, No. 4, July 27, 1998
“Year 2000 Compliance – Tax Issues, Year 2000 Computer Problems – Managing Risk and Legal Issues”, Insight, July 1998
“Taxation & Y2000”, Bennett Jones Verchere Year 2000 Comment, Summer 1998
“Stop-Loss Saga”, Canadian Tax Highlights, Vol. 6, No. 1, January 20, 1998
“Exchangeable Shares in Cross-Border Acquisitions”, Panel on International Mergers and Acquisitions Involving US Acquirors and Canadian Targets, Committee on Foreign Activities of US Taxpayers, Tax Section, American Bar Association, San Francisco, August 1, 1997
“Taxation and the Internet”, Bennett Jones Verchere Internet Comment, Summer 1997
“An Introduction to Canadian Income Tax, Tax and the Civil Litigator: Protecting Your Client… and Yourself”, Continuing Education (CBAO), May 1997
“Case Comment: The McNichol Case: GAAR – Round 1 to the Crown”, 7 Tax Law Update, No. 3, February 1997
“The New Film and Video Tax Credit and Multimedia”, Bennett Jones Verchere Entertainment Comment, p. 6, Winter 1997
“June 20, 1996 Technical Amendments Respecting Taxable Canadian Property and Foreign Property”, 7 Tax Law Update, No. 2, November 1996
“Newco Won’t Miss Out” (with Doug McFadyen), Canadian Tax Highlights, Vol. 4, No. 9, September 17, 1996
“If Not directly” (with Bernard Morris), Canadian Tax Highlights, Vol. 4, No. 6, June 18, 1996
“US Interest Allocation” (with Doug McFadyen), Canadian Tax Highlights, Vol. 4, No. 5, May 21, 1996
“Changes to the Canada-U.S. Tax Treaty” (with Doug McFadyen), CMA Magazine, Vol. 68. No. 10, December 1995
“Debt Forgiveness”, CMA Magazine, Vol. 69, No. 6, July/August 1995
“Relocating Employees and Mortgage Interest Subsidies”, Canadian Tax Journal, Vol. 43, No. 2, March/April 1995
“A Matter of Privilege”, CMA Magazine, Vol. 69, No. 2, March 1995
“Tax Considerations in Canada-US Executive Transfer, Executive Transfers: New Strategies in Relocating Key Executives and Personnel”, Canadian Institute, September 1994
“Debt Forgiveness Issues”, Canadian Tax Highlights, Vol. 2, No. 9, September 21, 1994
“Gone But Not Forgotten”, 124 CA Magazine, No. 12, December 1991
“Tax Planning for Departure from Canada”, Canadian Tax Journal, Vol. 39, No. 1, 1991