Peter practises primarily in the area of taxation. His tax practice encompasses the full range of tax planning and implementation for corporation and individuals.
Peter has significant experience in structuring tax-effective corporate and commercial transactions, including mergers and acquisitions, divestitures, and corporate reorganizations. He plays an integral role in the planning and implementation of securities offering and other corporate finance transactions. He also advises regularly on the tax aspects of compensation and incentive plans.
In the area of international transactions, Peter has worked for many of the firm's clients engaged in international business operations, and he regularly advises on the tax elements of inbound and outbound business transactions and structures.
Peter's practice includes a significant element of individual and closely-held business tax planning, including trust and estate tax planning.
Peter has made numerous presentations on tax topics, and he has taught the International Transactions course as adjunct professor at the University of British Columbia (Law School).
Recent tax responsibilities in the areas of cross-border structures and financings, various business acquisitions, securities offerings and international estate planning.
Recent representative work on behalf of clients includes the following:
- Acted for Teck Resources in the completion of a public offering in the United States of US$2 billion in aggregate principal amount of new senior unsecured notes, July 2011.
- Acted for Primero Mining Corp. in its merger with Northgate Minerals Corp. creating a $1.2 billion gold producer, July 2011.
- Acted for Richfield Ventures Corp. on its acquisition by New Gold Inc. by way of a plan of arrangement, April 2011.
- Acted for Teck Resources Limited in the completion of a private placement offering in the U.S. and Canada of US$4.225 billion in aggregate principal amount of senior secured notes, May 2009.
- Represented several PRC–based businesses in achieving tax-efficient Canada/PRC business structures, 2009 – 2010.
- Acted for Kraft Canada Inc. when it completed the sale of its Post cereal brand assets to a subsidiary of Ralcorp Holdings, Inc., August 2008.
- Acted for the special committee of the board of directors of Gemcom Software International Inc. in its acquisition by a vehicle indirectly owned by affiliates of JMI Equity Fund VI, L.P., Carlyle Venture Partners III, L.P. and Pala Investments Holdings Limited for approximately $190 million, July 2008.
- Assisted Northern Dynasty Minerals Ltd. in a joint venture with Anglo American plc to develop the Pebble Project in Alaska, July 2007.
- Acted for West Fraser Timber Co. Ltd in its acquisition of U.S. lumber business, March 2007.
- Represented Great Canadian Gaming Corp. to secure a C$200 million revolving credit facility and a US$170 million term loan and to issue US$170 million senior subordinated notes for gross proceeds of C$600 million, January 2007.
- Assisted Sierra Systems Group Inc. in its acquisition by Golden Gate Capital, January 2007.
- Acted for Continental Minerals Corporation in its merger with Great China Mining, December 2006.
Hong Kong - Canada tax treaty in force
budget 2013: broadening the application of Canada's thin-capitalization rules
budget 2013: international tax compliance
budget 2013: further restrictions on loss trading
budget 2013: deconstructing derivatives – capturing "character conversion transactions"
budget 2013: proposed consultation on changes to the income tax rate applicable to trusts and estates
budget 2013: synthetic dispositions
budget 2013: attribution rules and non-resident trusts
budget 2013: changes to personal income tax rules
budget 2013: enhanced SR&ED enforcement measures announced
budget 2013: capital cost allowance enhancements unveiled
budget 2013: changes to the taxation of resource industries
Hong Kong and Canada sign income tax treaty
TCC rules on taxation of break fees
budget 2012: new "foreign affiliate dumping" measures introduced
budget 2012: expansion of "prohibited investment" and "advantage" rules to retirement compensation arrangements ("RCAs")
budget 2012: changes to the tax rules for partnerships
budget 2012: transfer pricing amendments proposed
budget 2012: government moves to further expand the tax shelter rules
budget 2012: tightening of the "thin capitalization" rules unveiled
budget 2012: changes to the taxation of resource industries
budget 2012: flexibility for eligible dividend designations introduced
BC HST referendum
budget 2011: extension of the super flow-through share program
Withholding Obligations on Option Exercise Effective January 1, 2011
Revival of Unlimited Liability Companies
Law Note - New Options for Contractors
Law Note - Protocol to the Canada-U.S. Tax Treaty
Protocol to the Canada-U.S. Tax Treaty
Alternative Structures for U.S. Investment in Canada
Using an NSULC for U.S. Investment in Canada
- Queen's University, LLB - 1985
Year Of Call
- Called to the British Columbia bar - 1990
- Called to the Alberta bar - 1986
mergers and acquisitions
trusts and estates
sales and commodity taxation
structuring and formation
oil and gas
Directorships and Professional Associations
- Vancouver Bar Association
- Canadian Bar Association
- Canadian Tax Foundation
- International Bar Association
- International Fiscal Association
- Society of Trust and Estate Practitioners
- Past member, Vancouver Board of Trade Federal Budget Task Force
- Past member, B.C. Chamber of Commerce Finance and Taxation Committee
- Peter has taught the International Transactions course as adjunct professor at the University of British Columbia (Law School).
Awards & Rankings
- Listed in Who's Who Legal: Canada 2010 Report on Canada's Leading Business Lawyers (Corporate Tax).