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Todd Miller practises tax law with an emphasis on domestic and cross-border financing transactions (public and private), transfer pricing and international tax treaty matters, securities offerings, and mergers and acquisitions. He also provides counsel on reorganizations and business divestitures, and representation before the Tax Court of Canada.

With a broad scope of expertise, Todd provides advice on matters relating to private equity investments, joint venture / partnership agreements, estate planning and employee compensation. Assisting clients in a range of sectors including banking and manufacturing, he also provides advice on the taxation of charities and other non-profit organizations.

Todd is a regular author and speaker on a variety of tax matters such as cross-border business acquisition strategies, outbound planning for Canadian multinationals and partnership planning opportunities. He is a member of the Canadian Tax Foundation and the Canadian branch of the International Fiscal Association and a national leader of McMillan’s Tax Group.




News


Media Mentions


Rankings & Recognition

  • Listed in the Legal500 Canada 2020 as a “Recommended Lawyer” – Tax

Directorships & Affiliations

  • Canadian Bar Association
  • Canadian Tax Foundation
  • International Fiscal Association (Canadian Branch)

Education & Admissions

1995
Called to the Ontario bar
1993
LLB Osgoode Hall Law School
1993
BA, Economics York University

Publications

  • “Canadian Branch Profits Tax – Challenging the Denial of Treaty-Benefits for US LLCs,” TerraLex Connections Newsletter (January 2014)
  • “Canada: Audit Guide,” World Transfer Pricing 2014 – International Tax Review (October 2013)
  • “Canadian Q&A chapter for the 11th edition of the Practical Law Company Employee Share Plans Multi-Jurisdictional Guide” (October 2012)
  • “The New RRSP/RRIF Anti-Avoidance Regime: a Roadmap and Tips for the Unwary,” Taxation of Executive Compensation and Retirement Journal (April 2012)

Insights by Todd A. Miller (4 Posts)

Featured Insight

Budget 2021: Expansion of Mandatory Disclosure Rules

Budget 2021 proposes to significantly expand the mandatory disclosure rules contained in the Income Tax Act.

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Apr 23, 2021
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 2016: Significant International Tax Proposals Unveiled

Budget 2016: Significant International Tax Proposals Unveiled

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Mar 31, 2016
Featured Insight

Budget 2015: Tax-Free Savings Accounts – A Welcome Contribution Limit Increase, but “Prohibited Investment” Rules Remain a Concern

Budget 2015 proposes to increase the TFSA annual contribution limit from January 1, 2015. The TFSA annual contribution limit will no longer be indexed to inflation.

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Apr 29, 2015