Lyne Gaulin

CPA, CA, CPA (Illinois), LL.B.

Partner

Contact

Phone: 416.646.7396
Address: 181 Bay St., Suite 3320 - Bay Wellington Tower
Toronto, ON M5J 2T3

Services:

Tax

Lyne Gaulin is a seasoned tax practitioner with over 23 years of experience in providing advice on Canadian, cross-border and international tax matters to private and public companies, partnerships, trusts, investment and infrastructure funds, and REITs, among others. Lyne is a tax lawyer and practiced with major law firms in downtown Toronto prior to joining Richter.

Lyne has particular expertise in advising clients on tax planning and tax aspects of reorganizations and restructurings, acquisitions, divestitures, mergers, inbound and outbound structuring, takeovers, privatization, securitization, going public, financing, securities offerings and private placements. She works closely with clients to implement tax efficient structures and transactions that meet their particular objectives.

Fields of expertise

  • – Canadian, cross-border and international tax
  • – Reorganizations and restructuring
  • – M&A transactions
  • – Inbound and outbound structuring
  • – Financing, securities offerings and private placements
  • – Going public and privatization

Industries

  • – REITs and real estate
  • – Financial services
  • – Franchises
  • – Ecommerce
  • – Investment and infrastructure funds
  • – Manufacturing and distribution
  • – Technology
  • – Pharmaceutical and biomedical
  • – Oil and gas
  • – Mining

Professional Affiliations and Community Involvement

  • Law Society of Upper Canada - member 
  • Canadian Bar Association - member
  • Ontario Bar Association - member
  • Canadian Tax Foundation - member
  • American Bar Association - member
  • International Fiscal Association - member

Academic Background 

  • Chartered Professional Accountant, (CPA, CA) Ontario 
  • Certified Public Accountant (CPA), State of Illinois, USA 
  • Bachelor of Laws (LL.B.), Summa Cum Laude, University of Ottawa and Call to the Bar in Ontario 
  • B.Com. (with Honours), University of Ottawa
  • License in Accounting (L.S. Compt.), Laval University

Public Recognition 

  • Tax Executives Institute, Inc., “Proposed Amendments to Foreign Affiliate Dumping Rules”, November 2013
  • Law Society of Upper Canada event “Practice Gems: Essentials of the Privately Held Company”, Co-chair, September 2013
  • Canadian Life and Health Insurance Association Tax Officers Annual Conference on “Corporate and Trust Residence under Tax Treaties”, May 2010
  • Canadian Life and Health Insurance Association Tax Officers Annual Conference on “Debt Restructuring Transactions”, May 2009

Publications and Media

  • Author. “Multinational Canadian Federal Revised Anti-Avoidance Back-to-Back Loan Arrangement Proposals Provide Some Relief for Certain Financing Transactions,” published in Taxnetpro, Lexology and Mondaq. September 2014
  • Author. “Canadian Federal Court of Appeal Finds Anti-Avoidance Rule Applicable to Foreign Affiliates Has Limited Scope,” published in Practical International Tax Strategies (Carswell), Lexology and Mondaq. May 2014
  • Author. “OECD Base Erosion and Profit Shifting (“BEPS”) Action Plan: Action 1 – Addressing Tax Challenges of Digital Economy,” published in Lexology and Mondaq. April 2014
  • Co-author. “Supreme Court of Canada Considers Tax Regime and Common Law Principles Applicable to Amalgamations,” published in Lexology and Mondaq. December 2013
  • Co-author. “TCC Upholds Tax Benefits of Cross-Border Refinancing Involving Foreign Affiliates,” published in Practical International Tax Strategies (Carswell). August 2013
  • Co-author. “Overview of Limitation on Benefits Article in Canada-US Tax Treaty,” published in Lexology. April 2013
  • Co-author. “Overview of New Canada-Hong Kong Tax Treaty,” published in Lexology. April 2013
  • Co-author. “Tax Treatment of Break Fees from Recipient’s Perspective,” published in Lexology. November 2012
  • Co-author. “Foreign Affiliate Dumping Transactions,” published in Taxnetpro and Lexology. November 2012
  • Co-author, “Pertinent Loan or Indebtedness Regime,” published in Taxnetpro and Lexology. November 2012
  • Co-author. “Thin Capitalization Regime,” published in Taxnetpro and Lexology. November 2012
  • Author. “Copthorne Decision: Supreme Court of Canada Unanimously Applies GAAR,” published in Lexology. June 2012
  • Co-author. “CRA Guidance on Whether Canadian Captive Service Subsidiary Constitutes PE of Foreign Parent,” published in Lexology. December 2011
  • Author. “Cross-Border Tax: Canada-US Tax Treaty Update: CRA Views on Treaty Benefits on Dividends Paid by Canadian ULCs,” published in The 2011 Lexpert/American Lawyer Guide to the Leading 500 Lawyers in Canada the Canadian Corporate Counsel Association publication, Taxnetpro and Lexology. Fall 2010
  • Author. “Cross-Border Tax: Canada-US Tax Treaty Update – CRA Views on Treaty Entitlement on Canadian Source Income and Profit  for US LLC Shareholders,” published in Lexology. October 2010

Lyne is a frequent author and speaker on various tax topics at meetings, seminars and conferences organized by the Canadian Insurance Accountants Association, the Canadian Life and Health Insurance Association, Tax Executive Institute Inc., Miller Thomson LLP and PwC, among others.