Toronto 416.865.7266 education and year of call Called to the Ontario bar - 2007 University of Toronto, JD (Hons.) - 2006 University of Toronto, MA - 2001 Queen's University, BA (Hons.) (1st Class) - 2000 Part I of the Canadian Institute of Chartered Accountants' In Depth Tax Course - 2008 practice areas tax business taxation cross-border taxation sales and commodity taxation tax litigation and advocacy investment funds and asset management profile Carl is a member of McMillan's Tax Group. Carl provides advice to both Canadian and foreign clients on all aspects of domestic and international tax planning, compliance and dispute resolution. Carl assists clients in structuring domestic and international commercial acquisitions, divestitures, reorganizations and business combinations. He also regularly advises investment funds and asset managers on the establishment and administration of tax-efficient investment vehicles and has assisted with the offering of a large number of investment funds and structured products. Carl also counsels clients on the tax aspects of establishing businesses in Canada and on managing the tax implications of their ongoing business operations, including with respect to employee compensation, tax reporting and compliance. In addition to income tax matters, Carl also advises clients on commodity tax matters, particularly with respect to the goods and services tax/harmonized sales tax. Carl regularly speaks on a variety of tax matters and is a regular contributor of case comments to the Canadian Tax Journal. directorships and professional associations Ontario Bar Association Canadian Tax Foundation representative transactions Acted for HKSC Developments L.P. in connection with the Ontario Highway Services Centres Project to design, build, McMillan LLP Lawyers Vancouver Calgary Toronto Ottawa Montréal Hong Kong mcmillan.ca 1/7
finance and maintain and operate 23 existing service centres across the corridors of Highways 400 and 401. Acted for Picton Mahoney Tactical Income Fund in connection with its $156 million initial public offering in October 2012 Acted for Toronto Hydro in connection with its $1 billion MTN program and subsequent offerings of debentures. Acted for Century Mining Corporation in its business combination by way of plan of arrangement with White Tiger Gold Ltd. Acted for Detour Gold in connection with its acquisition of Trade Winds Ventures Inc. Acted for Horizons Enhanced U.S. Equity Income Fund in connection with a $30 million initial public offering in June 2011 Acted for Horizons Gold Yield Fund in connection with its $50.3 million initial public offering in December 2010 and its subsequent $10 million offering (re-opening) in April 2011. Acted for the agents in connection with Star Portfolio Corp.'s $87 million initial public offering in October 2010. community involvement Carl helps families with children being treated at the Hospital for Sick Children resolve tax disputes with the Canada Revenue Agency, as part of Pro Bono Law Ontario's Children's Hospitals Projects. publications April 2016 Budget 2016: Reporting of "Grandfathered" New Home Sales March 2016 New Québec Tax Certificate Requirement for Québec Construction Contractors and Employee Placement Agencies March 2016 Budget 2016: Significant Changes to the Taxation of Linked Notes Announced March 2016 Budget 2016: New Rules Targeting "Back-To-Back" Arrangements McMillan LLP Lawyers Vancouver Calgary Toronto Ottawa Montréal Hong Kong mcmillan.ca 2/7
January 2016 Tax Withholding Obligations of Non-Resident Employers: Further Exemption Details Released January 2016 Taiwan Canada Tax Arrangement Released October 2015 The New Home HST Rebate Beware the Traps for the Unwary September 2015 Third Party Penalties under the Income Tax Act Survive Constitutional Challenge August 2015 Government can Impose Penalties on Large Businesses for Deficiently Reporting Recapture of Input Tax Credits ("ITCs") July 2015 Reduction of Input Tax Credit ("ITC") Recapture Rate for Ontario Portion of HST ("OHST") starting July 1, 2015 April 2015 Budget 2015: New Rules Target "Synthetic Equity Arrangements" November 2014 GST/HST Closely Related Election Amendments Tips & Traps November 2014 UPDATE: Amendments to Thin Cap and Withholdings Tax Rules: Good News for Lenders, Better News for Borrowers Tax & Financial Services Bulletin August 2014 Alchemy in Reverse": McKesson Canada Corporation v. The Queen Canadian Tax Journal, (2014) Vol. 62, No. 3 July 2014 Tax Court Gives Guidance on Contemporaneous Documentation Requirement for Transfer Pricing McMillan LLP Lawyers Vancouver Calgary Toronto Ottawa Montréal Hong Kong mcmillan.ca 3/7
June 2014 Canadian Branch Profits Tax Challenging The Denial Of Treaty-Benefits For US LLCS June 2014 Accessing Input Tax Credits ("ITCs") of Holding Companies and Partners and Structuring of Partnerships to Reduce GST/HST Costs February 2014 Budget 2014: GST/HST Measures February 2014 Budget 2014: Significant Tax Changes Affecting the Canadian Resource and Energy Sector January 2014 Eligibility for Input Tax Credit ("ITC") Claims on Initial Public Offering ("IPO") and Placement Expenses and Beyond January 2014 Canadian Branch Profits Tax - Challenging the Denial of Treaty- Benefits for US LLCs TerraLex Connections Newsletter November 2013 Capital Gain Versus Income: Flying Into Fog CAE Inc. v. Canada Canadian Tax Journal, (2013) Vol. 61, No. 3 October 2013 GST refund claim made by A OK Payday Loans Inc. ("AOK") not A OK July 2013 Government releases revised transitional rules for 2013 "character conversion" measures March 2013 Budget 2013: GST/HST and customs tariff measures March 2013 Budget 2013: changes to personal income tax rules McMillan LLP Lawyers Vancouver Calgary Toronto Ottawa Montréal Hong Kong mcmillan.ca 4/7
October 2012 SCC resolves interaction between garnishment and bankruptcy provisions June 2012 Finance proposes amendments to the "prohibited investment" rules March 2012 Budget 2012: tightening of the "thin capitalization" rules unveiled March 2012 Budget 2012: changes to the taxation of resource industries January 2012 Commodity Tax/Customs 2012 LEXPERT/American Lawyer Guide to the Leading 500 Lawyers in Canada October 2011 Further changes to new RRSP/RRIF anti-avoidance rules introduced 2011 Unsuccessful Attack on Foreign Tax Credit Generator 4145356 Canada Limited v. The Queen 2011 TCC 220 Canadian Tax Journal (2011) 59:3, 547-70 October 2010 Interest Stripping Not Subject to GAAR Lehigh Cement Limited v Canada Case Comment: Canadian Tax Journal, (2010) Vol. 58, No 3 July 2010 Canada chapter in: Getting the Deal Through - Mining 2010 Reproduced with permission from Law Business Research. First published in Getting the Deal Through - Mining - 2010, (published in June 2010). For more information visit www.gettingthedealthrough.com July 2010 Finance announces changes to HST rules for funds McMillan Client Advisory June 2010 Significant Proposed HST Changes for Funds and their Managers McMillan Client Advisory McMillan LLP Lawyers Vancouver Calgary Toronto Ottawa Montréal Hong Kong mcmillan.ca 5/7
June 2010 We Didn't Mean It: Mistake and Rescission Stone's Jewellery Ltd. v. Arora Canadian Tax Journal, (2010) Vol. 58, No. 2 July 2009 Canada chapter in: Getting the Deal Through - Mining 2009 Law Business Research presentations November 2015 Recent Transactions of Interest and Significant Tax Developments Affecting Mergers and Acquisitions Canadian Tax Foundation - 67th Annual Conference, Montreal, Quebec September 24, 2015 Practical Tax Considerations for Equity Compensation Plans Federated Press: 13 th Taxation of Executive Compensation and Retirement Course February 4, 2015 HST Tips and Traps for Lawyers Ontario Bar Association's Institute 2015 November 18, 2014 HST Issues of Interest - Taxation of Sales of "Vacant Land" Taxation Issues for Real Estate Transactions Conference, Law Society of Upper Canada October 29, 2014 FATCA Workshop for Portfolio Managers Portfolio Management Association of Canada September 16, 2014 FATCA: A Portfolio Manager's Guide to Navigating Uncharted Waters Compliance Officers' Network Meeting, Portfolio Management Association of Canada November 13, 2013 The Corporate Counsel's Guide to Managing Tax Disputes and Mitigating Tax Risk McMillan Corporate Counsel Series October 16, 2012 Key Tax Issues for Corporate Counsel: Identifying and Managing Tax Risk Corporate Counsel Tax Presentation, McMillan LLP September 2011 Securing & Sustaining 'Mutual Fund Trust' Status - Tips & Traps Portfolio Management Association of Canada Seminar McMillan LLP Lawyers Vancouver Calgary Toronto Ottawa Montréal Hong Kong mcmillan.ca 6/7
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