Gowling WLG’s Tax team consists of thirty-two professionals practicing across Canada, the majority of who are concentrated in Toronto. The group
provides a complete, comprehensive portfolio of tax services; however, transactional tax matters make up a significant volume of its work. The firm serves both domestic and foreign clients.
Over the research period, the
Gowling team
advised
Leucrotta Exploration
in one of the largest oil & gas
transactions for Canada that year.
The complex
transaction involved
the
transfer of C$500 million in
outstanding
shares to Vermillion Energy,
and a newly formed Montney
company Coelacanth Energy.
In the Tax Controversy space,
Gowling is
currently acting for Electronic Warfare Association in a matter
of audit defense valued at over C$5.5 million.
“Good project management, strong expertise in the area and a good network.”
“The
Gowling team had strong technical knowledge in the issues being reviewed by the CRA. They were also good at teaming with EY in developing a coordinated audit defence.”
“The tax group at Gowling pointed out an opportunity for significant tax benefits based on structuring the transaction a certain way, which ultimately saved us a lot of money.
Since these tax benefits were based on specific Canadian rules, none of us at Savvas would have known about the opportunity for these savings.”
“Responsive, creative, detail oriented.”
“Very collegial and knowledgeable; respect and meet deadlines; great insights.”
“Excellent advice, consice and easy to understand. Very well thought out strategy.”
“Always working hard to improve the tax attributes of the transaction.”
“Responsive and creative.”
“Economic
comparables, negotiation with Competent Authorities, technical
assistance with transfer pricing audit queries.
Work is completed on
a timely basis.”
“Knowledgeable of tax audit process with respect to CRA acting on behalf of foreign tax regime. Capably directed and coordinated our work to enable
Gowling to appropriately respond to the tax queries.”
“Gowling WLG Canada, specifically, John Sorensen, Partner, is very technically knowledgeable in respect of international tax issues and clearly has extensive experience in dealing with both the federal and provincial tax authorities in Canada. In addition to his technical
proficiency, John exemplifies professionalism in all respects and is a strong writer and communicator. It is a pleasure to work with him.”
“The lawyers we work with are definitely subject matter experts, very collaborative and find practical solutions.”
“Creativity, efficiency and ease of communication have been exceptional.”
“Detail tax research, creative tax planning.”
“Our products are highly structured, extremely complex and 100% unique (there is nothing else like them available in Canada or elsewhere, to our knowledge), with many moving pieces (e.g., involving arms-length, 3rd party loans, underlying derivative investments, including various reference portfolios, cross-border considerations, charity law aspects, relying on various complex tax provisions and related case law to maximize tax efficiency and safety, etc.) that must be considered both separately and in tandem when any change to any particular aspect of the product is made.
Our products are structured as limited partnerships and so a very deep knowledge of partnership law and partnership tax law is
required, as well as the related potential impact to securities law, secured transactions law, corporate-commercial law, etc. from our tax counsel.
Ash Gupta’s skill, experience and instincts are simply outstanding, allowing him and his team to
provide efficient and exemplary advice as needed and to spot and solve potential issues and/or obstacles as they arise.
The structuring Gowlings did to enhance the tax efficiency of our main product was unprecedented (since our product is so unique) and required Gowlings to think through many unique issues.
When an issue unexpectedly arose on this latter matter at the 11th hour, Gowlings worked around the clock to address the issue and
come up with an effective and efficient tax solution that allowed us to launch the product as planned late during the 2022 calendar year extending the selling cycle and increasing our sales and potential future opportunities.
The termination of our legacy products (some dating back up to 20 years) was particularly complex and called for Gowlings to carefully consider whether the general anti-avoidance rule (a notoriously difficult-to-apply test) could apply to an unprecedented transaction involving the exchange of thousands of legacy limited partnership units (from numerous different offerings) for new limited partnership units in a master partnership, that met very specific conditions and resulted in an extremely tax efficient termination for our investors. In the often uncertain and shifting environment of tax law in Canada today, we needed a high degree of certainty that the intended resolution would achieve the desired and expected result for our investors. Ash Gupta’s team at Gowlings was able to
provide the support and comfort we and our investors
required.”
Our business, which is a tough one, was extremely successfully this year and we do not exaggerate when we say it would not have been possible without Gowlings’ valued support, guidance, advice, skill,
talent and experience.”
“Tenacious with the tardy tax authorities, keep us informed, good contacts, practical advice rather than just legal theory.”
“Great and timely customer service.”
