PROFILE
Ian is a Partner in the firm's Tax Group. His tax practice involves advising on a broad range of tax matters, including corporate reorganizations, cross-border transactions, acquisitions and divestitures, financings, personal tax and estate planning, tax dispute resolution and voluntary disclosures. Ian also advises First Nations on tax structuring associated with investment funds, economic development vehicles and the formation of trusts and limited partnerships.
Publications
MAY 21 2020
Doing Business in Canada - 2020 Edition
This comprehensive guide provides an overview of the legal framework governing Canadian business operations and outlines key considerations for investing and conducting business in Canada. Find up-to-date information on the following topics:
- Types of Business Organizations
- Directors' Liabilities
- Foreign Investment and Anti-Competition Legislation
- Bankruptcy and Insolvency
- Securities Regulation
- Sales and Transfer Taxes
- Income Taxes
- Customs and Excise Duties
- Intellectual Property
- Investment Incentives
- Immigration Restrictions for Non-Canadians
- Employment Law
- Environmental Law
- Electronic Commerce
- The French Language Requirements in the Province of Quebec
APRIL 19 2020
Working From Home in the Time of COVID-19
Given the large numbers of people, both employed and self-employed, who are currently working from home in order to comply with physical distancing guidelines, it is useful to review the rules surrounding the deduction of home office expenses, for purposes of the Income Tax Act (Canada) (herein the "Act"). While there are many similarities, there are some subtle differences in the restrictions that apply to employees earning employment income versus self-employed individuals earning income from carrying on a business at home.
APRIL 14 2020
Canada Emergency Wage Subsidy - What Does the Legislation Say?
On April 11, 2020, the federal government passed Bill C-14 (A second Act respecting certain measures in response to COVID-19; the "Act") which amended the Income Tax Act to implement the 75% COVID-19 emergency wage subsidy first announced by the government on March 27, 2020.
On a high-level basis, the Act provides a 75% wage subsidy (up to a maximum of $847 per week) to employers in respect of employees that continue to be employed during the crisis. As always, however, the devil is in the details and a careful examination of the legislation is needed to determine whether any given employer will qualify for the subsidy.
MARCH 19 2020
Federal Government Announces Support Plan for Canadian Households and Business
On March 18, 2020, the Federal Government released an $82 billion package in financial support - $27 billion in direct relief to workers and business, and $55 billion to meet liquidity needs of Canadian businesses and households through the deferral of certain income tax obligations.
OCTOBER 12 2018
Beware of State and Local Taxes on Remote Sales into the United States
The recent decision of the Supreme Court of the United States (the "USSC") in South Dakota v. Wayfair, Inc. (No. 17-494), has substantially expanded the taxation powers of the U.S. States to collect sales tax.
DECEMBER 19 2017
Revised Income Splitting Proposals
On July 18, 2017, the Department of Finance released a series of controversial tax proposals aimed at closing perceived tax "loopholes" that involve the taxation of private corporations and their shareholders...
OCTOBER 12 2017
Significant Restrictions To The Voluntary Disclosures Program
The Voluntary Disclosures Program (VDP) is a "tax amnesty" program administered by the Canada Revenue Agency ("CRA")...
JULY 19 2017
Major Proposed Changes To The Taxation Of Private Corporations And To Severely Limit Income Splitting
The Federal Government released a set of proposals on July 18, 2017 that, in the government’s words, are designed to "improve fairness in the tax system by closing loopholes and addressing tax planning strategies" and to ensure "that the richest Canadians pay their fair share of taxes and that people in similar circumstances pay similar amounts of tax" (a summary of the proposals and related documentation can be found at http://www.fin.gc.ca/n17/17-066-eng.asp)...
APRIL 24 2017
Dollars and Sense Spring 2017
Ontario announced a 15% tax on the purchase or acquisition of an interest in residential property located in the Greater Golden Horseshoe ("GGH") by individuals who are not citizens or permanent residents of Canada and by foreign corporations ("foreign entities") and certain taxable trustees.
APRIL 19 2017
Reporting Now Required To Claim The Principal Residence Exemption ("PRE")
The long-standing administrative policy of the CRA was not to require an individual to report the disposition of a principal residence if there was no capital gain remaining after applying the PRE...
OCTOBER 17 2016
Dollars and Sense Fall 2016
The principal residence exemption ("PRE") is one of the most significant "tax breaks" available under the Income Tax Act (Canada) (the "Act")...
JULY 18 2016
Dollars and Sense Summer 2016
The 2015 Federal Budget contained significant amendments to section 55 of the Income Tax Act (Canada) (the "Act"). These amendments recently became law and will generally apply retroactively to dividends received after April 20, 2015
OCTOBER 29 2015
FR Dollars and Sense
MAY 13 2014
FR Dollars and Sense
Practice Areas
Representative Work
LexPert Big Deals
ConceptWave Software Inc.
- Acted as counsel to ConceptWave Software Inc. and certain founding shareholders on the September 2012 acquisition by Ericsson Canada Inc.
Canadian Solar Solutions Inc.
- Advised on tax matters for Canadian Solar Solutions Inc. in connection with December 2011 master purchase and sale agreement with TransCanada Corp. for turnkey solar farms.
- Acting for Issuers and Agents on numerous flow-through share financings.
- Representation of domestic and foreign clients on outbound and inbound translation structuring.
- Acting in real estate investment and divestiture structuring matters.
- Advising on tax matters for investment funds, including Mutual Fund Trust, Mutual Fund Corporations and Limited Partnerships.
- Advising on purchase and sale of Canadian private corporations.
- Advising with respect to corporate reorganizations, financings, acquisitions and divestitures.
- Advising Owner-Managers and high net worth individuals on tax and estate planning matters.
- Advising Estate-Trustees on post-mortem tax planning, including "pipeline" reorganizations.
Publications
- FR Dollars and Sense
- Canadian Real Estate Income Tax Guide (Co-Author/Editor Wolters Kluwer)
- A quarterly looseleaf and electronic publication on the income tax and GST/HST aspects of real estate - Tax Topics (Wolters Kluwer)
- Various articles from 1996 to 2012 - The Controlling Mind - The Tax Perspective (Carswell - Contributing Author)
- Canadian Taxation of Real Estate (4th Edition), 2004 (Co-Author with Michael Atlas, C.A., CCH Canadian Limited)
- Reasonable Expectation of Profit and Other Heresies (2002 Ontario Tax Conference)
Speaking Engagements
- Presentations at accounting firms on income tax, GST/HST and Land Transfer Tax matters
- Buying or Selling a Business: An Overview of Tax Considerations (Ontario Bar Association - Institute 2013)
- GST Aspects of Certain Arm's Length and Non-Arm's Length Transfers of Real Estate and Different Business Transactions
- Ontario Bar Association program entitled "Taxation of Real Estate Transactions - A User's Guide", September 18, 2007
Memberships
- Canadian Tax Foundation
- Society of Trust and Estate Practitioners (STEP)
- Guitar Society of Toronto - Past President
- Canadian Bar Association
- Law Society of Ontario
Education
- Admitted to Ontario Bar, 1989
- Osgoode Hall Law School, LL.B., 1987
- McGill University, B. Comm., 1984
