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Tax

Our tax team has established several market-leading tax-assisted financing vehicles for our clients. We are creative and proactive.

Whether you going through a merger, acquisition or company restructuring, get proactive guidance from us on domestic and cross-border tax strategies. We can help you reach your business goals by giving you comprehensive and insightful tax advice.

We have experience in using limited partnerships, joint ventures, trusts and hybrid vehicles when we structure business ventures. 

Cutting-edge tax advice

Over the years, we have been at the forefront of creating innovative tax structures. This includes the first large-scale investments by pension fund resource corporations in the oil and gas industry and the first use of royalty trusts in a public financing context.

What we do

Get advice from us on:

  • Mergers and acquisitions and resource taxation
  • Reorganizations, restructurings and financings
  • Flow‑through shares
  • Transactions involving royalty trusts, income funds and REITs
  • Domestic and international equipment leasing and financing syndications
  • Tax loss utilization transactions
  • Partnerships and joint ventures
  • Private equity investment funds, venture capital, and startup companies
  • Tax aspects of insolvency and debt restructuring
  • Employment compensation issues
  • Offshore technology rights
  • Stock options and executive compensation
  • GST issues
  • Tax planning for start-up businesses and family-owned businesses

Our tax lawyers have played a pivotal role in several organizations including the Canadian Tax Foundation and the Canadian Petroleum Tax Society.

Experience with tax disputes of all types

With a deep bench strength in dispute resolution, our tax litigation team can help you resolve your tax dispute. Whether you are an individual or a business, we can advise you on the best course of action to resolve your dispute quickly and efficiently. If your matter goes to trial, our litigators have appeared before all levels of tax court – from the Tax Court of Canada and Federal Courts to the Alberta Court of Queen's Bench.

What our clients say

"The team explains things in layman terms and always looks for the most efficient solution. They have excellent tax lawyers who are very knowledgeable with corporate taxation." – Legal 500 Canada 2022

Representative work

ARC Resources Ltd.'s $8.1 billion combination

Counsel to ARC Resources Ltd. in its $8.1 billion strategic Montney combination with Seven Generations Energy, resulting in ARC becoming Canada's largest condensate producer, third-largest natural gas producer and sixth-largest upstream energy company.

Greenfire Acquisition Corporation acquisition of Japan Canada Oil Sands Limited

Counsel to Greenfire Acquisition Corporation in its acquisition of all of the shares of Japan Canada Oil Sands Limited, which has a working interest in the Hangingstone facility in Alberta, for an undisclosed amount.

WestBlock Capital Inc. acquisition by LUXXFOLIO Holdings Inc.

Counsel to WestBlock Capital Inc., a cryptocurrency mining company, in its acquisition by LUXXFOLIO Holdings Inc., a digital infrastructure provider based in Canada for an undisclosed sum.

Kicking Horse Oil & Gas Ltd.'s $300 million acquisition by Whitecap Resources Inc

Counsel to Kicking Horse Oil & Gas Ltd., a portfolio company of Quantum Energy Partners, in its $300 million acquisition by Whitecap Resources Inc.

Whitecap Resources Inc's $300 million acquisition of Kicking Horse Oil & Gas Ltd.

Counsel to Whitecap Resources Inc. in its indirect acquisition of Kicking Horse Oil & Gas Ltd., a portfolio company of Quantum Energy Partners, for $300 million.

Alaris Equity Partners Income Trust $95 million financing

Counsel to Alaris Equity Partners Income Trust in a bought deal financing of 5,909,375 trust units for gross proceeds of $94,550,000.

Peloton's acquisition of Cevian Technologies

Counsel to Peloton in its acquisition of Cevian Technologies, a cloud-based software company, for an undisclosed amount.

Scoular Company's sale of its edible bean business for US $25 million

Canadian counsel to the Scoular Company, a large, privately-owned US agricultural commodities trading company, in the sale of its edible bean business, which included processing plants in St. Hilaire, Minnesota, U.S.; Plum Coulee and Morden, Manitoba; and receiving stations in Garske and Grafton, North Dakota, U.S., to Cooperative Elevator Co., for approximately US $25 million.

Alaris Royalty Corp. $100 million financing

Counsel to Alaris Royalty Corp. on its $100,000,000 financing of 5.5% senior unsecured subordinated debentures.

Restructuring of Westmorland Coal Company and its Alberta mining operations

Acted as local transactional agent counsel in regard to the cross border, Chapter 11 driven, restructuring of Westmorland Coal Company and its Alberta mining operations through its Alberta subsidiary corporations. This engagement involved several stages of debt restructuring, a complex tax structured credit bid purchase of all the shares of Westmoreland's Alberta subsidiaries, and various transactional logistics necessitated by Westmoreland's convoluted international corporate structure and Alberta's regulatory environment.

Read Case Study

MEG Energy Corp.'s hostile tender offer from Husky Energy

Counsel to MEG, a Canadian oil sands producer, and its board of directors in response to the unsolicited tender offer by Husky Energy. Husky sought to acquire the entire share capital of MEG for approximately $6 billion.

Gear Energy Ltd.'s $70 million acquisition

Counsel to Gear Energy Ltd. regarding a $70 million plan of arrangement acquisition of Steppe Resources Inc.

$2.8 billion acquisition of Raging River Exploration Inc.

Counsel to Raging River Exploration Inc., a Canadian oil producer, in the $2.8 billion strategic acquisition.

NuVista Energy Ltd.'s acquisition of pipestone business of Cenovus Energy Inc.

Counsel to NuVista in the $625 million acquisition of the Cenovus Pipestone Partnership, which holds assets in the Pipestone area of Northwest Alberta.

$232 million acquisition of Canadian Helicopters Limited

Counsel to Don Wall and CHL Heli-Acquisition Company Ltd. in the $232 million acquisition of HNZ Group Inc. (Canadian Helicopters Limited).

Enerflex Ltd.'s acquisition of Mesa Compression, LLC

Counsel to Enerflex Ltd., through the U.S. entity Enerflex Energy Systems Inc., in its US$106 million acquisition of U.S. based contract compression business, Mesa Compression, LLC.

Canyon Services Group Inc.'s acquisition by Trican Well Service Ltd.

Counsel to Canyon Services Group in the $637 million acquisition by Trican.

Sale of Marathon Oil Canada Corporation to CNRL

Counsel to Marathon Oil Corporation in the US$2.5 billion sale of Marathon Oil Canada Corporation to Canadian Natural Resources Limited and Shell Canada Energy.

Canadian Natural Resources Limited's $1.8 billion note offering

Counsel to the dealers in a $1.8 billion public offering of medium term notes by Canadian Natural Resources Limited.

$220 million acquisition of UGR Blair Creek Ltd.

Counsel to UGR Blair Creek Ltd. in its $220 million acquisition by Painted Pony Petroleum Ltd.

Savanna Energy Services Corp.'s hostile takeover defence

Counsel to Savanna Energy Services in the defence of a $450 million hostile takeover bid by Total Energy Services Inc.

Spur Resources Ltd.'s $407 million acquisition

Counsel to Spur Resources Ltd. in the $407.5 million acquisition by Tamarack Valley Energy Ltd.

Tourmaline Oil Corp.'s $1.3 billion acquisition of energy assets

Counsel to Tourmaline Oil Corp. in the $1.37 billion acquisition of strategic assets located in the Alberta Deep Basin and the north east British Columbia Gundy area from Shell Canada Energy.

FirstEnergy Capital Corp.'s acquisition by GMP Capital Inc.

Counsel to FirstEnergy Capital Corp. in its $99 million acquisition by GMP Capital Inc..

Inter Pipeline Ltd.'s $600 million public offering

Counsel to Inter Pipeline Ltd. in a $600 million public offering of 22,430,000 subscription receipts.

Axia NetMedia Corporation's $272 million acquisition

Counsel to Axia NetMedia Corporation in the $272 million acquisition by Partners Group in a going private transaction completed by plan of arrangement.

Yoho Resources Inc. going private transaction

Counsel to Yoho Resources Inc. in the $30.5 million going private transaction led by One Stone Energy Partners LP.

VolkerWessels Canada Ltd. acquisition of a private construction and highway maintenance company

Counsel to VolkerWessels Canada Ltd. (Volker Stevin) in connection with its acquisition of a private construction and highway maintenance company, Lakes District Maintenance Ltd.

$595 million energy asset acquisition by Whitecap Resources Inc.

Counsel to Whitecap Resources Inc. in the $595 million acquisition of premium oil assets in southwest Saskatchewan from Husky Energy Inc.

Murphy Oil Canada Ltd.'s disposition of natural gas assets in British Columbia

Counsel to Murphy Oil Canada Ltd., Canadian subsidiary of Murphy Oil Corporation, in the $538 million disposition of the Tupper Main and Tupper West gas plants and associated pipelines in northeastern British Columbia to Enbridge G and P Canada Limited Partnership, a subsidiary of Enbridge Inc.

PrairieSky Royalty Ltd.'s $1.8 billion asset acquisition

Counsel to PrairieSky Royalty Ltd. in $1.8 billion acquisition of royalty assets from Canadian Natural Resources Limited.

Carmel Bay Exploration Ltd.'s line of credit from Quantum Energy Partners

Counsel to Carmel Bay in the $200 million equity line of credit established from Quantum.

Ag Growth International Inc.'s $221 million acquisition

Counsel to Ag Growth International Inc. in the $221 million acquisition of the Westeel division of Vicwest Inc.

Freehold Royalties Ltd.'s $373 million public offering

Counsel to Freehold Royalties Ltd.in its $373 million public offering of 20,700,000 common shares and the $33 million private placement of 1,833,334 common shares.

Mullen Group Ltd. acquisition of Gardewine Group Limited Partnership

Counsel to Mullen Group Ltd. in the $172 million acquisition of Manitoba-based Gardewine Group.

Spartan Energy Corp. acquisition of Renegade Petroleum Ltd.

Counsel to Renegade Petroleum Ltd. in the $495 million acquisition by Spartan Energy Corp. pursuant to a plan of arrangement.

Progress Energy Canada Ltd.'s acquisition of energy assets

Counsel to Progress Energy Canada Ltd. in the $1.5 billion acquisition of part of Talisman Energy Ltd.'s Montney acreage in northeast British Columbia.

Baytex Energy Corp.'s $1.5 billion financing

Counsel to Baytex Energy Corp. in its $1.5 billion public offering of 38,433,000 subscription receipts.

$5.2 billion acquisition of Progress Energy Resources Corp.

Counsel to Progress Energy Resources Corp. in the $5.2 billion acquisition by PETRONAS, the Malaysian national oil company.

Crescent Point Energy Corp.'s $640 million acquisition

Counsel to Wild Stream Exploration Inc. in the $640 million acquisition by Crescent Point Energy Corp.

Athabasca Oil Sands Corp.'s energy asset sale and joint venture

Counsel to Athabasca Oil Sands Corp. in the $1.9 billion sale of 60% interest in McKay & Dover Oil Sands assets to PetroChina International Investment Company Limited and negotiated related joint venture.

Triwest Capital Partners acquisition of NCSG Crane & Heavy Haul Corporation

Counsel to Triwest Capital Partners and Alberta Teachers’ Retirement Fund in connection with the acquisition of a majority interest in NCSG Crane & Heavy Haul Corporation.

US Development Group LLC's joint venture with Gibson Energy

Counsel to US Development Group LLC in its 50/50 joint venture with Gibson Energy to advance the financing, development and construction of a Diluent Recovery Unit in Hardisty, Alberta.

Advising Deans Knight on a tax dispute

Counsel to Deans Knight Income Corporation in a case that involves whether the deduction of tax attributes can be properly denied by the CRA on the basis of the general anti-avoidance rule in the Income Tax Act (Canada). (Deans Knight Income Corporation v. Her Majesty the Queen)

International Petroleum Corporation acquisition of oil and natural gas assets from Cenovus Energy Inc.

Counsel to International Petroleum Corporation in the acquisition of oil and natural gas assets in Suffield and Alderson areas of southern Alberta from Cenovus Energy Inc. for proceeds of $512 million plus an additional deferred contingent amount of $36 million