Executive summary
Lorne Saltman is a partner at Gardiner Roberts and head of the firm’s Tax Group. He has extensive experience across a wide range of tax matters, with a practice that spans both domestic and international tax planning. Lorne regularly advises high-net-worth individuals and businesses on wealth preservation, cross-border acquisitions and financings, corporate reorganizations, real estate ventures, and the establishment of offshore trusts and private foundations.
Lorne also has a strong track record in resolving disputes with tax authorities at both the federal and provincial levels, including representing clients in tax litigation. He is valued for his strategic approach and his ability to navigate complex tax issues efficiently and effectively.
In addition, Lorne brings deep experience in domestic and international tax and estate planning for entrepreneurs and corporate executives. His work includes estate freezes of private corporations, the establishment and administration of family and discretionary trusts, and the creation of private charitable foundations, all tailored to support long-term planning and succession goals.
Expertise
Representative work
- Advised Canadian real estate developer on structure of $40 million joint venture with development partners
- Provided legal advice on transfer pricing policies of Canadian‑based telecommunications corporation with significant pension plan deficit in foreign affiliate
- Established captive insurance company in Barbados for a Canadian‑based real estate development company with U.S. operations
- Advised a successful Canadian interior decorator on his acquisition of U.S. real property interests
- Advised an ultra‑high‑net‑worth Canadian resident on a departure tax plan involving a private charitable foundation and life insurance
- Advised a terminally‑ill doctor on reorganizing his affairs, including share and debt capital reorganizations, settling an Alter Ego Trust and Principal Residence Trust, and revising Wills to include testamentary trusts
- Established a Barbados‑based trust and corporate structure to protect business and investment assets of Venezuelan families
- Negotiated successfully with the Canada Revenue Agency in connection with voluntary disclosures of unreported income for an individual with investment income from a foreign jurisdiction with a blocked currency, for a computer software company whose managing director appropriated assets and funds from the company, and for a Canadian‑based multinational corporate group with defective international tax planning
- Worked with litigation counsel to obtain Rectification Order to prevent realization of unintended $24 million capital gain in defective corporate reorganization
- Worked with high-net-worth families to develop a governance structure and succession plan
- Worked with high-net-worth clients immigrating to Canada to establish tax-free “Granny Trusts” and tax-effective corporate structures
Insights
Publications
- ExxonMobil Canada Resources Company v. The King, Case Study – 20 August 2026
- Canada v. Hutchison Whampoa Luxembourg Holdings S.A.R.L. sub nom Husky Energy Inc. v. The King, Case Study – 19 December 2025
- Active Asset Management v. The King Case Study – 29 July 2024
- Paletta et al v. The Queen, Case Study – 31 December 2019
- Alta Energy Luxembourg S.A.R.L. v. The Queen – 12 September 2019
- Canadian Update on Cross-Border Tax Planning – 29 May 2019
- Cross‐Border Giving Strategies and the New Disclosure Rules – 23 May 2019
- Case Comment: Cameco Corporation v. The Queen – 1 January 2019
- An Update on Rectifications – 15 November 2018
- Highlights of Recent Tax-Related Cases – 20 September 2018
- Canada’s Implementation of the Multilateral Convention to Prevent Base Erosion and Profit Shifting – 17 July 2018
- Highlights From The Federal/Provincial Budgets – 17 May 2018
- Highlights of American Tax Reform for Canadians – 7 February 2018
- Update on the Tax Proposals for Private Corporations – 28 November 2017
- Update on Canada’s Implementation of the OECD’s Plans to Combat Tax Avoidance – 9 October 2017
- Taxation of Investment Income, Voluntary Disclosure Program, and Automatic Exchange of Information – 14 September 2017
- Canadians with International Assets – 17 May 2017
- Minister of National Revenue v. BP Canada Energy Company – Appeal Re: Disclosure of Tax Accrual Working Papers – 26 April 2017
- Canadians with Connections to the U.S.A. – 7 December 2016
- Common Tax Pitfalls to Avoid in Real Estate Investments – 11 November 2016
- Rectification – A Useful but not Universal Tool to Remedy Mistakes – 26 May 2016
- OECD’s Base Erosion and Profit Shifting – 5 May 2016
- Update on Recent Trust Tax Changes and Planning Opportunities – 3 March 2016
- Canadian Investment in U.S. Real Estate – Structuring for Commercial and Personal Investments – 3 April 2014
- Tax Planning for Canadians Doing Business in Latin America, presentation for the Canadian‑British Chamber of Trade and Commerce – 2 February 2013
- Preserve Assets with a Principal Residence Trust, Rogers Media: Advisor.ca – 1 January 2013
Blogs
News
Memberships and recognition
Board memberships
- Canadian Jewish Civil Rights Association, Secretary/Treasurer, and Director
- Advocates for Civil Liberties Inc., President and Director
Professional memberships
- American Bar Association, Business Law Section, Taxation Committee, Advisory Panel
- American Bar Foundation
- Canadian Bar Association
- Canadian Tax Foundation
- Hague Academy of International Law
- International Bar Association
- International Commission of Jurists
- International Fiscal Association
- International Tax Planning Association
- Ontario Bar Association
- Society of Trust and Estate Practitioners (STEP)
- Toronto Chinese Community Services Association
Recognition
- Best Lawyers in Canada 2022-2026 for Tax Law
- Best Lawyers in Canada 2024-2026 for Trusts and Estates Law