Mike Flatters copy

Michael J. Flatters


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Queen's University, Bachelor of Laws, 1977

Yale University, Bachelor of Arts, 1974

Bar admission: Alberta 1981 and Ontario 1979
Aerospace, Agribusiness, food and beverage, Franchises, dealerships and distributorships, Government and not for profit, Oil and gas
Practice areas:
Business law, Commercial agreements, Wills and estate administration, Corporate reorganizations, Regulatory, environmental and Indigenous-Related Legal Issues, Tax litigation, Tax


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


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

Representative work

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.

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.


Recent honours and recognition

Recognized by Best Lawyers in Canada in Tax Law (2006-2010, 2013-2017, 2019-2023)

Named in the Canadian Legal Lexpert Directory recommended lawyer in corporate tax (2005-2010)