199 Bay St, Suite 4000, Commerce Court West, Toronto, ON
Year called to bar: 1991 (ON)
Senior counsel in the Blakes Tax group; previously led the group as National Practice Group Leader for over 15 years. Over his career, Jeffrey has provided strategic tax advice and assisted clients in managing tax audits and resolving tax disputes. Jeffrey is widely known and respected by advisors and government officials in the Canadian and international tax communities. Former Chair of the National Taxation Section (CBA); Former Co-Chair of the CBA/CPA Canada Joint Committee on Taxation; Advisor to the Board of Governors of the Canadian Tax Foundation and Chair Emeritus of the Lex Mundi Tax Practice Group. Co-Chair of C.D. Howe Institute Fiscal and Tax Competitiveness Council. Co-author: Deeper into the Knight: Exploring Deans Knight and Its Effects on the Canadian GAAR, Tax Notes International, September 25, 2023, p. 1639. Writes/speaks frequently for the Canadian Tax Foundation, C.D. Howe Institute, University of Toronto, Osgoode Hall Law School; Editor - Perspectives on Tax Law & Policy.
Great-West Lifeco Inc., a subsidiary of Power Financial Corporation, itself a subsidiary of Power Corporation of Canada, successfully closed a substantial issuer bid to purchase $2 billion of its common shares
On July 31, 2018, Galaxy Digital Holdings Ltd. (Galaxy) completed an arrangement transaction pursuant to which Bradmer Pharmaceuticals Inc., Galaxy Digital LP and First Coin Capital Corp. combined to form a new enterprise in the blockchain, digital asset and cryptocurrency space.
On May 4, 2018, Frontier Capital completed the acquisition of Agreement Express Inc. and its subsidiary corporations (AEX) through a plan of arrangement. The investment was made through Frontier Capital’s US$700 million Frontier Fund V
Minto Apartment Real Estate Investment Trust (the REIT) (TSX: MI.UN) completed its initial public offering of 15,863,100 trust units at a price of $14.50 per unit (the Offering). The Offering raised gross proceeds of $230,014,950, including through exercise of the underwriters’ over-allotment option in full which option exercise was completed July 10. The units trade on the Toronto Stock Exchange under the symbol MI.UN.
On January 23, 2018, H&R Real Estate Investment Trust (H&R REIT) completed a public offering of $250 million principal amount of 3.416 per cent Series O senior unsecured debentures due January 23, 2023.
On November 1, 2017, The Washington Cos. (Washington), a group of privately held North American mining, industrial and transportation businesses founded by industrialist and entrepreneur Dennis R. Washington, completed its acquisition of Dominion Diamond Corp. (Dominion) for approximately $1.5 billion.
On April 24, 2017, Lundin Petroleum AB, a Swedish oil and gas company, completed the cross-border spin-off of its then wholly owned Canadian subsidiary International Petroleum Corporation by way of distribution of all the shares of International Petroleum to the shareholders of Lundin Petroleum.
In the culmination of a complex cross-border bankruptcy sales and auction process, on February 28, 2017, Performance Sports Group Ltd. (PSG) announced the completion of the sale of substantially all of its assets to an investor group led by Sagard Holdings Inc. (Sagard) and Fairfax Financial Holdings Limited (Fairfax) for US$575 million, subject to certain adjustments, and the assumption of related operating liabilities.
On November 7, 2016, H&R Real Estate Investment Trust (“H&R REIT”) completed a public offering of $200-million principal amount of 2.923 per cent Series L senior unsecured debentures due May 6, 2022.
On April 1, 2016, TransCanada Corporation closed a bought deal offering of subscription receipts in Canada and the United States for aggregate gross proceeds of $4.4 billion, which, at the time, constituted the largest bought deal offering in Canadian history
Scotiabank completed the acquisition of a 20 per cent equity interest in the financial services business of Canadian Tire Corporation, Limited for $500 million in cash. As part of the new business partnership, Scotiabank has agreed to provide a funding commitment to the financial services business of up to $2.25 billion and the parties have entered into a marketing program agreement to pursue joint marketing initiatives.
Element Financial Corporation acquired the assets and operations of PHH Arval, PHH Corporation's North American fleet management services business, for a purchase price of US$1.4 billion in cash. Element also assumed PHH's obligations under the PHH fleet securitization programs in the US and Canada.
On July 27, 2010, H&R Real Estate Investment Trust (“H&R REIT”) completed a bought deal financing pursuant to which it issued $100,000,000 aggregate principal amount of 5.90 per cent Series D convertible unsecured subordinated debentures due June 30, 2020.
On May 9, 2007, H&R Real Estate Investment Trust (H&R REIT) completed a bought deal financing pursuant to which it issued approximately 8.86 million trust units, including 0.86 million trust units issued pursuant to an over-allotment option, for total gross proceeds of approximately $224.2 million.