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Michael Friedman is widely recognized as a leading tax lawyer. He provides advice on a diverse range of domestic and international tax matters. Michael has exceptional expertise in structuring commercial acquisitions, divestitures, reorganizations and business combinations. Acting for clients in a range of industries, Michael also advises on the tax aspects of ongoing business operations, including employee compensation and stock option planning, tax and reporting compliance, transfer pricing and voluntary disclosures.

As a senior member of the firm’s tax law team, Michael has been involved in the development of innovative tax-efficient investment fund structures for asset managers, and private equity and investment funds, including master-feeder funds, switch funds, and specialized return funds. He assists on the formation of institutional and specialized structured products tailored for domestic and offshore investors, specialized portfolios, and a variety of investment techniques. He also has extensive experience in the efficient structuring of hedging transactions.

Successfully representing his clients in tax disputes with the Canada Revenue Agency and the provincial revenue authorities, Michael has also appeared before the Tax Court of Canada and the Federal Court of Appeal. He is the national leader of the firm’s Tax Group.



Representative Matters

  • Acted for Public Mobile Inc. in connection with the acquisition of the telecommunication company by Thomvest Seed Capital Inc.
  • Acted for Detour Gold Corporation in its approximately $84 million acquisition of Trade Winds Ventures Inc. by way of a plan of arrangement
  • Acted for the underwriting syndicate in a bought deal equity offering for Perseus Mining Limited with gross proceeds of $93.4 million
  • Acted for Goldstone Resources Inc. in the approximate $104 million purchase thereof by Premier Gold Mines Limited
  • Acted for the dealer managers in connection with a $1.18 billion rights offering by Ivanhoe Mines Ltd.

Speaking Engagements

Canadian Investor in an Increasingly Globally Regulated World - PMAC National Conference & Annual Meeting, Toronto, Ontario

November 2015

The Characteristics and Uses of Limited Partnerships Osgoode Professional Development: The Short Course on Partnerships, Limited Partnerships and Joint Ventures, Toronto, Ontario

November 2015

Associated Affiliated and Related: The Implications Ontario Tax Conference, Canadian Tax Foundation, Toronto, Ontario

October 2015

FATCA Workshop for Portfolio Managers Portfolio Management Association of Canada, Co-presented with Deloitte, Amoranto Consulting, and Kaye Scholer LLP

October 2014

The Future of Business Taxation in Canada: An Insider's Perspective Canadian Corporate Counsel Association

April 2014

Crossing the 49th Parallel: Best Practices in Canada-US Corporate Transactions Association of Corporate Counsel, Co-presented with Edwards Wildman

March 2014

Emerging Managers Seminar Series: Doing Business Offshore Alternative Investment Management Association, Co-presented with KPMG, Walkers and Waratah Capital Advisors

September 2013

Navigating the Minefield: An Advisor's Guide to Penalty Taxes and Other Tax Pitfalls Presentation to the IAIC Annual Conference

September 2012

The Characteristics and Uses of Limited Partnerships Osgoode Professional Development: The Short Course on Partnerships, Limited Partnerships and Joint Ventures, Toronto, Ontario

October 2010

The Characteristics and Uses of Limited Partnerships Osgoode Professional Development: The Short Course on Partnerships, Limited Partnerships and Joint Ventures, Toronto, Ontario

October 2009

Challenges when Structuring Cross-Border Transactions and Political Solutions Presented at the AIJA May Conference, Miami, Florida

May 2008

Income Trusts Revisited: The Canadian Income Tax Implications of the Proposed "SIFT" Rules Federated Press: Tax Effective Private Equity & Investment Funds Course, Toronto, Ontario

June 2007
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Teaching Engagements

  • Adjunct Faculty – “Integrative Legal Strategy” – Rotman School of Management at the University of Toronto – 2005-2006

News


Media Mentions


Ranking & Recognitions


Community Involvement

  • Michael is a strong supporter of a number of charitable causes and pro bono initiatives. Most notably, Michael is actively involved in the Family Legal Health Program, a joint pro bono initiative between McMillan LLP and Pro Bono Law Ontario that provides free legal services to patients of the Hospital for Sick Children in Toronto and their families.

Directorships & Affiliations

  • Canadian Tax Foundation

Education & Admissions

2002
Called to the Ontario bar
2000
MBAUniversity of Toronto
2000
LLBUniversity of Toronto

Publications

Insights by Michael Friedman (51 Posts)

Featured Insight

Oral Agreements Worth More Than the Paper They’re Written On

The Federal Court recently ruled that taxpayers may be required to disclose descriptions of records that should have been kept, including oral contracts.

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Oct 4, 2021
Featured Insight

Budget 2021: Government Targets Strategies to Avoid Tax Debts

Budget 2021 proposes new legislation to target strategies to avoid tax liabilities that would otherwise arise under section 160 of the Income Tax Act.

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Apr 23, 2021
Featured Insight

Budget 2021: Government Targets Hybrid Mismatch Arrangements

Budget 2021 proposes new legislation to target hybrid mismatch arrangements

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Apr 23, 2021
Featured Insight

Budget 2021: CRA to be Granted the Authority to Compel Oral Responses

Budget 2021 proposes to grant the Canada Revenue Agency the authority to demand oral responses in the course of an audit.

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Apr 23, 2021
Featured Insight

Budget 2021: “Registered Investment” Taxation Rules Relaxed

Budget 2021 announced legislative changes that will provide welcome relief to trusts and corporations that are “registered investments”.

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Apr 23, 2021
Featured Insight

Budget 2021: Extension of Wage & Rent Subsidies

Budget 2021 proposes the extension of both the Canada Emergency Wage Subsidy (“CEWS”) and the Canada Emergency Rent Subsidy (“CERS”).

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Apr 23, 2021
Featured Insight

CRA Simplifies Process for Deducting Work from Home Expenses

The CRA has announced two new permitted approaches for employers to claim deductions in respect of home office expenses incurred in 2020.

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Dec 22, 2020
Featured Insight

Government Proposes Relief for Issuers of Flow-Through Shares

This article discusses the government's proposal to extend the time for junior mining companies to spend amounts raised on issuance of flow-through shares.

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Jul 28, 2020
Featured Insight

Government Proposes Fundamental Changes to the Canada Emergency Wage Subsidy

This article provides a detailed analysis of the proposed changes to the Canada Emergency Wage Subsidy announced by the Government on July 17, 2020.

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Jul 21, 2020
Featured Insight

Will CRA Pursue Directors for Deferred GST/HST?

We discuss steps corporate directors can take to protect themselves from personal liability for deferred GST/HST remittances.

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Jun 10, 2020
Featured Insight

Government Expands Entitlement to the Canada Emergency Wage Subsidy

Government Expands Entitlement to the Canada Emergency Wage Subsidy

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May 20, 2020
Featured Insight

Calculating the CEWS: Meaning of “Leave With Pay” Leaves Questions Unanswered

As part of the Canada Emergency Wage Subsidy, employers with eligible employees on "leave with pay" can potentially claim an increased subsidy.

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Apr 23, 2020
Featured Insight

The Canada Emergency Wage Subsidy: Increased Assistance on the Horizon

The Canada Emergency Wage Subsidy offers government subsidies of up to 75% of qualifying employee wages.

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Apr 13, 2020
Featured Insight

Managing Tax Matters in the Midst of the COVID-­19 Pandemic

As the COVID­19 pandemic disrupts business operations around the world, in­house tax professionals must strive to adapt to rapidly changing tax requirements and new compliance challenges.

Mar 6, 2020
Featured Insight

New Proposed Legislation to Refine Mutual Fund “Allocation to Redeemers” Methodology

Budget 2019 proposed new rules to combat tax strategies employed by certain mutual fund trusts to disproportionately allocate capital gains to redeeming unitholders under the so-called “allocation to redeemers” methodology.

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Jul 30, 2019
Featured Insight

Budget 2018: Tempered Private Company Passive Investment Income Changes Unveiled

Budget 2018 introduced measures to limit the tax deferral advantages perceived to be afforded to private company investment income.

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Mar 9, 2018
Featured Insight

Budget 2018: A Blast from the Past – Tiered-Partnership Trap Reinstated

Budget 2018 proposes to tighten so-called "at-risk" rules in the Income Tax Act to limit losses that may flow through a tiered limited partnership structure.

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Mar 8, 2018
Featured Insight

Budget 2018: Cross Border Tax Planning Measures Targeted

Budget 2018 introduced several international tax measures designed to address certain taxpayer transactions.

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Mar 7, 2018
Featured Insight

Budget 2018: Cannabis Taxation Plans Move Forward

Budget 2018 plans to tax cannabis and will include the full range of regular taxes such as income tax on business profits, GST on product sales and the property taxes and licence fees

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Mar 6, 2018
Featured Insight

Budget 2018: Reassessment Periods and Information Sharing Expanded

Budget 2018 to amend the Income Tax Act to afford Canada Revenue Agency time to reassess certain taxpayers and more latitude to share information with foreign authorities

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Mar 5, 2018
Featured Insight

Budget 2018: Government Proceeds with “Investment Limited Partnership” GST/HST Measures and Holding Corporation Consultations

Budget 2018 reaffirms Government desire to subject services rendered by general partners of investment limited partnerships to GST/HST treatment and intention to examine holding corporation rule

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Mar 4, 2018
Featured Insight

Budget 2018: Mineral Exploration Tax Credit Extended and Tax Support for Clean Energy Expanded

Budget 2018 extends mineral exploration tax credit for so-called flow through shares for another year and eligibility for accelerated capital cost allowances for investments in clean energy equipment

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Mar 2, 2018
Featured Insight

Private Corporation Tax Proposals: “Striking a Balance” or Introducing Greater Complexity?

Private Corporation Tax Proposals: "Striking a Balance" or Introducing Greater Complexity?

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Oct 19, 2017
Featured Insight

A New Tax on Investment Funds: Distributions to General Partners (GPs) of “Investment Limited Partnerships” Possibly Subject to GST/HST

A New Tax on Investment Funds: Distributions to General Partners (GPs) of "Investment Limited Partnerships" Possibly Subject to GST/HST

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Oct 2, 2017
Featured Insight

Further Changes to Ontario’s Land Transfer Tax Regime: Trust and Partnership Transparency on the Chopping Block

Further Changes to Ontario's Land Transfer Tax Regime: Trust and Partnership Transparency on the Chopping Block

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Jul 15, 2017
Featured Insight

Federal Government Proposes Fundamental Changes to the Voluntary Disclosures Program

Federal Government Proposes Fundamental Changes to the Voluntary Disclosures Program

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Jul 11, 2017
Featured Insight

Budget 2017: New Rules Governing the Taxation of Segregated Funds

Budget 2017: New Rules Governing the Taxation of Segregated Funds

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Mar 28, 2017
Featured Insight

Budget 2017: Tax Changes Affecting the Resource Industries

Budget 2017: Tax Changes Affecting the Resource affecting the oil & gas and mining industries

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Mar 28, 2017
Featured Insight

Budget 2017: “Switch” Fund Reorganization Rules Introduced

Budget 2017: "Switch" Fund Reorganization Rules Introduced

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Mar 15, 2017
Featured Insight

Doing Business in Canada – Key Canadian Tax Considerations

Doing Business in Canada - Key Canadian Tax Considerations

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Feb 8, 2017
Featured Insight

Canada Revenue Agency Poised to Limit Access to the Voluntary Disclosures Program

Canada Revenue Agency Poised to Limit Access to the Voluntary Disclosures Program

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Dec 29, 2016
Featured Insight

Offshore Investment Fund Property Rules Clarified by the Tax Court

Offshore Investment Fund Property Rules Clarified by the Tax Court

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Jul 28, 2016
Featured Insight

Canada Revenue Agency Frowns Upon the Use of US LLPs and LLLPs

Canada Revenue Agency Frowns Upon the Use of US LLPs and LLLPs

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Jul 12, 2016
Featured Insight

Budget 2016: Expanding Tax Support For Clean Energy

Budget 2016: Expanding Tax Support For Clean Energy

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Mar 31, 2016
Featured Insight

Budget 2016: Labour-Sponsored Venture Capital Corporations Tax Credit Re-Introduced

Budget 2016: Labour-Sponsored Venture Capital Corporations Tax Credit Re-Introduced

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Mar 31, 2016
Featured Insight

Budget 2016: Debt Parking Rules Expanded to Address Foreign Currency Denominated Debts

Budget 2016: debt parking rules expanded to address foreign currency denominated debts

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Mar 31, 2016
Featured Insight

Budget 2016: Taxation of Emissions Trading Activities Clarified

Budget 2016: Taxation of Emissions Trading Activities Clarified

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Mar 31, 2016
Featured Insight

Budget 2016: Eligible Capital Property Rules Revamped

Budget 2016: Eligible Capital Property Rules Revamped

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Mar 31, 2016
Featured Insight

Budget 2016: New Rules Governing the Taxation of “Switch Fund” Shares

Budget 2016 – New Rules Governing the Taxation of “Switch Fund” Shares

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Mar 31, 2016
Featured Insight

Number of Voluntary Disclosures Continues to Increase

Number of Voluntary Disclosures Continues to Increase

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Feb 2, 2016
Featured Insight

Tax Withholding Obligations of Non-Resident Employers: Further Exemption Details Released

Tax Withholding Obligations of Non-Resident Employers: Further Exemption Details Released

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Jan 28, 2016
Featured Insight

Taiwan – Canada Tax Arrangement Released

Taiwan – Canada Tax Arrangement Released

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Jan 25, 2016
Featured Insight

Are Changes to the Flow-Through Share Regime Around the Corner?

Are Changes to the Flow-Through Share Regime Around the Corner?

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Dec 10, 2015
Featured Insight

New Governments First Round of Tax Changes Introduced in Parliament

New Governments First Round of Tax Changes Introduced in Parliament

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Dec 9, 2015
Featured Insight

Significant Tax Changes on the Horizon

Significant Tax Changes on the Horizon

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Nov 20, 2015
Featured Insight

Budget 2015: Penalties for Tax Reporting Failures Modified

Budget 2015: Penalties for Tax Reporting Failures Modified

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Apr 28, 2015
Featured Insight

Budget 2014: Treaty Shopping

Budget 2014: Treaty Shopping

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Feb 21, 2014
Featured Insight

Budget 2014: Consultation on Eligible Capital Property

Budget 2014: Consultation on Eligible Capital Property

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Feb 14, 2014
Featured Insight

Budget 2013: international tax compliance

Budget 2013: international tax compliance

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Mar 26, 2013

Wood. v. Holden,: Clarifying the “Central Management and Control” Test

Wood. v. Holden: Clarifying the "Central Management and Control" Test

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Aug 1, 2005

BJ Services Company Canada v. The Queen – Capital Confusion: The Evolving Tax Characterization of Merger Costs

BJ Services Company Canada v. The Queen - Capital Confusion: The Evolving Tax Characterization of Merger Costs

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Jul 1, 2003