Lyne Gaulin

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

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

• 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.