Experience
Michael’s focus is on
Tax law
- Income tax and excise tax aspects of domestic and international corporate reorganizations, financings and commercial transactions
- Prepares and argues taxpayer's objections and appeals from domestic audits and reassessments in the Tax Court of Canada and Federal Court of Appeal
- Advises on corporate compensation plans and the registration and operation of registered pension plans and charities
- Advises on trust and litigation matters
Aboriginal law
- Advised on tax, corporate and commercial planning associated with the negotiation and implementation of comprehensive land claim agreements and impacts and benefits agreements
- Negotiated and drafted taxation, fiscal financing and own source revenue agreements on behalf of Aboriginal governments with the Government of Canada and Provincial and Territorial Governments
- Advised on interpretation of Impacts and Benefits, Revenue Sharing and Royalty Agreements with Industry proponents
- Advised on drafting, interpretation and administration of Trusts for settlement of Land Claim, Impacts and Benefits, Capital Monies and Commercial Settlement funds for benefit of Aboriginal beneficiaries
- Structured commercial arrangements among Indigenous owned commercial entities and Aboriginal Governments and Industry proponents
- Advised on behalf of Aboriginal applicants re submission of requests for Advanced Income Tax and Excise Tax Rulings with Canada Revenue Agency
- Advised on behalf of Aboriginal bodies with respect to interpretation and amendments to Income Tax and Excise Tax law with Department of Finance, Canada
Community involvement
Michael is the Director of the Horne Charitable Foundation.
Professional involvement
Michael is a past general editor of Taxation and Financing of Aboriginal Businesses in Canada (Carswell).
Professional associations
- Member, Law Society of Alberta
- Member, Canadian Bar Association
- Member, Calgary Bar Association
- Member, Canadian Petroleum Tax Society
- Member, Canadian Tax Foundation
- Member, International Fiscal Association
Presentations
Michael has lectured and written materials for professional and trade groups primarily in relation to income tax subjects and pension investments. He has also presented at various conferences, panels, seminars, and other events, including:
- Tax Developments Affecting the Purchase, Sale & Reorganization of a Business, Canadian Tax Foundation Annual Conference, November 2012
- Aboriginal Business Structures, The Canadian Tax Foundation, Prairie Tax Conference, 2006
- Income versus Capital Expenditures, The Canadian Tax Foundation, Prairie Tax Conference, May 2005
Awards
Recent honours and recognition
Recognized by Best Lawyers in Canada in Tax Law (2006-2010, 2013-2017, 2019-2025)
Named in the Canadian Legal Lexpert Directory recommended lawyer in corporate tax (2005-2010)