V. Daniel Jankovic
Partner | Calgary
Calgary: 403-260-9725

Dan has a combined tax planning and tax disputes practice.

Dan practises corporate income tax law and advises on domestic and international tax planning matters, with a particular focus on mergers and acquisitions, corporate reorganizations, investments by private equity and pension funds, divestitures, and debt restructurings. He also advises international clients looking to invest, commence or acquire business operations in Canada.

Dan frequently represents domestic and international clients in tax disputes with Canadian revenue authorities.

Dan is fluent in French and Serbo-Croat.

SELECT EXPERIENCE

Examples of recent significant transactions include:

  • Sale by Ontario Teachers' Pension Plan of equity interest in GCT Global Container Terminals Inc. to IFM Investors (an Australian investment management company) and British Columbia Investment Management Corporation

  • Trinidad Drilling Ltd. on its C$505-million acquisition of CanElson Drilling Inc.

  • Cenovus Energy Inc. on its C$17.7-billion acquisition of assets from ConocoPhillips

  • Successful settlement with the Canada Revenue Agency after filing a judicial review application for Imperial Oil Limited

  • Suncor Energy Inc. in connection with the C$1.13-billion sale of its Petro-Canada lubricants division to HollyFrontier Corporation

  • Agrium Inc. in connection with a series of acquisitions related to its retail agriculture and fertilizer businesses in Alberta and Saskatchewan

  • Solium Capital Inc. in its acquisition of Capshare’s cloud/web-based equity management platform assets

PUBLICATIONS
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Co-author: Canada: Application and Interpretation of the Principal Purpose Test
International Tax Review, February 2018.
Author: Country-by-Country Reporting Legislation Implemented in Canada
International Tax Review, January 2017.
Contributing Author: Country Report - Canada
Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructurings, Kluwer Law International B.V., Fourth Edition, Vol. 1, 2017.
Co-author: New Canadian Payroll Withholding Tax Exemption
International Tax Review, February 2016.
Co-author: Is There A Difference Between "Processing" And "Distribution" In The LNG Context?
Canadian Tax Journal, pp. 751-761, Vol. 63, No. 3, November 20, 2015.
Blakes Bulletin on Litigation & Dispute Resolution, November 2, 2015.
Co-author: Overview of the Proposed Amendments to Subsection 55(2)
Corporate Tax Planning Journal, Vol. XIII, No. 3, pp. 728-732, Federated Press, 2015.
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PROFESSIONAL APPEARANCES
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Co-presenter: Negotiating Tax Settlements
Canadian Tax Foundation, Preventing, Navigating & Resolving Tax Disputes Conference, Montréal, Quebec, May 24-25, 2018.
Co-presenter: International Tax Issues for Partnerships
International Fiscal Association (Canada Branch), 2018 Conference, Calgary, Alberta, May 15-16, 2018.
Presenter: Top 10 Tax Planning & Litigation Points
Tax Executives Institute, Inc., Calgary, Alberta, March 14, 2018.
Co-presenter: Cash Pooling Arrangements
Canadian Petroleum Tax Society Fall Lecture Series, Calgary, Alberta, November 9, 2017.
Presenter: Tax Considerations in Securities Transactions
Canadian Bar Association, Alberta Securities Section, Calgary, Alberta, October 18, 2017.
Co-presenter: Planning Your Commercial Transaction in Anticipation of a Tax Dispute
Canadian Petroleum Tax Society, Calgary, Alberta, June 2017.
Co-presenter: Corporate Reorganizations - A Primer
Canadian Tax Foundation, 68th National Conference Workshop, Calgary, Alberta, November 27, 2016.
Presenter: Update on Subsection 55(2)
Canadian Petroleum Tax Society, Annual Conference, Calgary, Alberta, October 27, 2016.
Presenter: Recent Canadian Elections & Tax Implications for the Oil & Gas Industry
2015 Argus Canadian NGL Summit, Argus Media Limited, Calgary, Alberta, November 3, 2015.
Co-presenter: Recent CRA Rulings & Interpretations
Canadian Petroleum Tax Society, Calgary, Alberta, October 21, 2015.
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