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Aideen Brennan

Aideen Brennan
Aideen Brennan Canadian Legal Advisor | Vancouver
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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)

Professional Activities

Aideen is a member of the Canadian Tax Foundation and the Canadian Bar Association, tax law section. Aideen is presently completing CPA Canada's In-Depth Tax Course for tax professionals and is currently in the third and final year of the program.

Professional Appearances
  • 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.

Admitted to the British Columbia Bar as a Canadian Legal Advisor - 2018
Admitted to the Quebec Bar - 2017
J.D., University of British Columbia - 2015
B.C.L./LL.B., McGill University - 2015
B.B.A. (Hon., First Class with Distinction, Finance and International Business), Simon Fraser University - 2012

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