Aideen Brennan
Canadian Legal Advisor | Vancouver
Vancouver: 604-631-3337

Aideen practises in all areas of Canadian and international income tax law and also advises on Québec income tax matters. Her tax advisory practice spans industries and sectors, including technology, consumer products, pharmaceutical, private equity, pension funds, shipping, mining, engineering, construction and real estate, and involves a broad range of tax planning matters, including private and public market deal structuring, LBOs, cross-border issues, and financing, as well as structuring various forms of equity-based compensation arrangements.

Aideen's dispute resolution and tax litigation work involves all stages of the audit and appeals process with the Canada Revenue Agency and Revenu Québec, including objections, negotiations and settlements. She also has experience in the context of large-scale international transfer pricing audits and submissions before administrative authorities and courts, including the Tax Court of Canada, Ontario Superior Court and Supreme Court of Canada.

Aideen articled in the Blakes Montreal office, joined as an associate, and has since continued her tax practice in the Vancouver office. While in Montreal, Aideen was seconded to one of the world largest beverage and brewing multinationals. Prior to joining Blakes, Aideen also worked in the corporate affairs department of one of Canada’s national railway companies, and later in the legal department of a large multinational Swiss pharmaceutical company.


Tax Planning

  • $50-million convertible debt private placement

  • Structuring of various investment funds and real estate LPs

  • Reorganization of large international, shipping group

  • Acquisition and disposition of shipping assets

  • Acquisition of mining assets, including significant tax attributes

  • Sale of aviation company, including tax issues related to executive compensation and buyouts

  • Creation of employee and executive stock option plans, restricted share plans and issues related to cash-out of stock options

  • Intra-group services and secondments by multinational pharmaceutical company

  • Canadian income tax considerations for offshore entities, including the application of the non-resident trusts rules and controlled foreign affiliate regime

Dispute Resolution and Tax Litigation

  • Tax audit and appeal of multinational engineering group concerning the deductibility of over C$19-million in transaction costs

  • Tax appeal of mining group concerning deductibility of over $7.2-million in transaction costs and over $10-million in transfer pricing adjustments

  • Tax appeal concerning reassessment of C$6.5-million in interest

  • International transfer pricing audit of one of the world’s largest media groups

  • Tax audit of law firm and tactfully managing issues of solicitor client privilege in connection thereto

  • Tax audit and submissions to CRA on behalf of portfolio manager reassessed in relations to trading activities and whether such activities constitute a business for Canadian income tax purposes

  • Applications under the voluntary disclosure program and issues related to offshore investments and compliance

  • Various tax audits and appeals related to employee taxable benefit and shareholder benefit issues

  • Taxpayer audits and reassessments under derivative assessment provision (s.160) of the Income Tax Act (Canada)

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Presenter: Nuts and Bolts - Important Tax Concepts for Common Transactions
Blakes Business Class, Vancouver, British Columbia, March 25, 2019.
Co-speaker: Dealing with Tax Officials: A Primer on Canadian Income Tax Administration, Enforcement and Appeals
Blakes CLE Seminar, October 26, 2017.
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