Executive Summary
Lorne Saltman is a Partner with Gardiner Roberts LLP. He has extensive experience in diverse areas of tax practice, including in-depth experience on both the international and domestic levels involving wealth preservation for high-net worth clients, cross-border acquisitions and financings, corporate reorganizations, real estate ventures, and the establishment of offshore trusts and private foundations.
He has a successful track record in resolving disputes with tax authorities at both the federal and provincial levels, including some experience in tax litigation.
Lorne has in-depth experience in tax and estate planning, both domestic and international, for entrepreneurs as well as corporate executives, involving estate freezing of private corporations, the settlement of family, discretionary trusts and the establishment of private charitable foundations.
Expertise
Representative Work
- Advised a Canadian bank on establishing referral agreements with selected independent trustees in tax-favoured jurisdictions for compliant, non-resident trusts for Canadians;
- Advised a Caribbean country on its tax treaty negotiations;
- Provided legal advice on transfer pricing policies of Canadian-based telecommunications corporation with significant pension plan deficit in foreign affiliate;
- Advised a multinational mining corporation on its $1.6 billion acquisition of assets from a multinational gold producer, and on its $2.1 billion acquisition of shares of another public mining corporation;
- Advised a public company on its conversion into a public income fund and with respect to ongoing issues;
- Established captive insurance companies in Barbados for a Canadian-based multinational in the steel manufacturing business and a Canadian-based real estate development company with U.S. operations;
- Developed a tax and corporate structure in Canada and the U.S.A. for a software development initiative between leading American software company and Canadian private equity fund;
- Established an estate freeze trust/corporate structure for partners in a new Canadian investment bank;
- 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;
- 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;
- Negotiated successfully with the Canada Revenue Agency in the settlement of a tax claim exceeding $6 million against a trio of world-famous entertainers, who used a complex tax structure in connection with performances in Canada.
Articles and Presentations
- Collins Family Trust Case Study - January 6, 2023
- The New Rules Limiting The Deductibility Of Interest And Financing Expenses - December 1, 2022
- Godcharles v. Québec Revenue Authority - July 8, 2022
- BEPS Action 1, Pillar 1 and Pillar 2: A Canadian Perspective - April 4, 2022
- OECD's Global Tax Reform 2021 - October 24, 2021
- AgraCity Ltd. v. The Queen, Case Study - November 23, 2020
- Paletta et al v. The Queen, Case Study - December 31, 2019
- Alta Energy Luxembourg S.A.R.L. v. The Queen - September 12, 2019
- Canadian Update on Cross-Border Tax Planning - May 29, 2019
- Cross-Border Giving Strategies and the New Disclosure Rules - May 23, 2019
- Case Comment: Cameco Corporation v. The Queen - January 1, 2019
- An Update on Rectifications - November 15, 2018
- Highlights of Recent Tax-Related Cases - September 20, 2018
- Canada's Implementation of the Multilateral Convention to Prevent Base Erosion and Profit Shifting - July 17, 2018
- Highlights From The Federal/Provincial Budgets - May 17, 2018
- Highlights of American Tax Reform for Canadians - February 7, 2018
- Update on the Tax Proposals for Private Corporations - November 28, 2017
- Update on Canada's Implementation of the OECD's Plans to Combat Tax Avoidance - October 9, 2017
- Taxation of Investment Income, Voluntary Disclosure Program, and Automatic Exchange of Information - September 14, 2017
- Canadians with International Assets - May 17, 2017
- Minister of National Revenue v. BP Canada Energy Company - Appeal Re: Disclosure of Tax Accrual Working Papers - April 26, 2017
- Canadians with Connections to the U.S.A. - December 7, 2016
- Common Tax Pitfalls to Avoid in Real Estate Investments - November 11, 2016
- The Bottom Line: "More to philanthropy than writing a cheque" - November 3, 2016
- Rectification – A Useful but not Universal Tool to Remedy Mistakes - May 26, 2016
- OECD's Base Erosion and Profit Shifting - May 5, 2016
- Update on Recent Trust Tax Changes and Planning Opportunities - March 3, 2016
- Commentary: Discovery Trust and Boettger Cases - January 6, 2016
- Commentary: Minister Of National Revenue v. BP Canada Energy Company - August 24, 2015
- Commentary: Public Television Association of Québec v. Minister of National Revenue - August 24, 2015
- OBA NYBA Cdn Investment in US Real Estate - October 10, 2014
- Tax Planning for Canadians Doing Business in Latin America - October 10, 2014
- Canadian Investment in U.S. Real Estate - Structuring for Commercial and Personal Investments - April 3, 2014
- Tax Planning for New Immigrants and Returning Residents - November 7, 2013
My Blog
- COVID-19 Provides Rare Opportunity for an Estate Freeze - April 13, 2020
Board Memberships
- Canadian Jewish Civil Rights Association, Secretary/Treasurer, and Director
- Advocates for Civil Liberties Inc., President and Director
Professional Involvement
- 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