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Amanda Heale

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Amanda’s deal experience includes advising:

  • Bayshore Capital on Broadridge’s US$300-million acquisition of RPM Technologies

  • TD Bank in connection with Air Canada’s acquisition of Aimia Canada

  • Hydro One Limited on its C$1.97-billion secondary offering of common shares

  • Hydro One Limited on its C$1.83-billion initial public offering

  • COM DEV in connection with its acquisition by a subsidiary of Honeywell International Inc. by way of a plan of arrangement and its spinoff of exactEarth Ltd.

  • Valeant Pharmaceuticals Inc. on its C$8.7-billion all cash acquisition of Bausch & Lomb

  • URS Corporation on its C$1.5-billion acquisition of Flint Energy Services Ltd.

  • Sterling Partners on its C$590-million acquisition of MOSAID Technologies Inc.

  • Equinox Minerals on its unsolicited bid for Lundin Mining and its acquisition agreement with Barrick Gold Corporation

  • Walter Energy on its C$3.3-billion acquisition of Western Coal Corp. by plan of arrangement

  • Kinross Gold Corporation on its C$7-billion acquisition of Red Back Mining Inc.

  • Magna International on its dual-class share capital reorganization by way of plan of arrangement

Amanda’s case experience includes representing:

  • Wheaton Precious Metals in the successful resolution of its transfer pricing dispute with the CRA, a “recharacterization” case and one of the most significant transfer pricing appeals in Canada

  • Cameco Corporation in the Tax Court of Canada in the first case to consider the interpretation and application of the transfer pricing “recharacterization” rules in paragraphs 247(2) (b) and (d), playing a lead role in formulating the taxpayer’s successful legal theory

  • The Toronto Dominion Bank in a successful judicial review and statutory appeal of decisions taken by the British Columbia Commissioner of Income Tax and the Minister of Finance in respect of an annual corporate tax return (TD Bank v. British Columbia (Commissioner of Income Tax))

  • McKesson Canada Corporation in its transfer pricing appeal to the Federal Court of Appeal (settled out of court)

  • GlaxoSmithKline Inc. in a successful appeal to the Supreme Court regarding the transfer price of the active ingredient in a branded pharmaceutical product (Canada v. GlaxoSmithKline Inc.)

Awards & Recognition

Amanda has been named a Lexpert Rising Star: Leading Lawyers Under 40 and a Rising Star: Tax in the Euromoney LMG Americas Women in Business Law Awards. She has also been recognized as a leading lawyer in the following publications:

  • Chambers Canada: Canada's Leading Lawyers for Business 2020 (Up and Coming: Tax: Litigation)

  • The Best Lawyers in Canada 2020 (Tax)

  • International Tax Review’s World Tax 2019 (Tax Controversy and Women in Tax)

  • Legal Media Group’s Guide to the World’s Leading Tax Lawyers 2019

  • Legal Media Group’s Guide to the World’s Leading Transfer Pricing Lawyers 2019

Professional Activities

Amanda is a member of the Canadian Branch Council of the International Fiscal Association and the CPA Joint Committee on Taxation of the Canadian Bar Association (CBA).

She is also a lecturer at the CBA’s annual Tax Law for Lawyers Conference and an adjunct professor at the University of Toronto Faculty of Law, where she teaches international tax law.

Professional Appearances
  • Speaker: Interest Deductibility: The Implementation of BEPS Action 4
    IFA International Tax Conference, International Fiscal Association Canada, Montréal, Quebec, May 14-15, 2019.
  • Speaker: Recent Developments/Judicial Trends in Transfer Pricing
    53rd Annual Canadian Tax Conference, Tax Executives Institute, Ottawa, Ontario, May 7, 2019.
  • Speaker: Managing Transfer Pricing Audits and Disputes Pre-Litigation
    Canadian Petroleum Tax Society, Calgary, Alberta, October 3, 2018.
  • Speaker: Strategic Considerations for Managing Tax Risk
    Tax Executives Institute, Vancouver, B.C., November 15, 2017.
  • Speaker: Transfer Pricing Litigation – The Next Battlefield
    72nd Annual Conference, Tax Executives Institute, Toronto, Ontario, October 22-25, 2017.
Education
Admitted to the Ontario Bar – 2005
J.D. (Silver Medallist, Dean’s Key Recipient), University of Toronto – 2004
B.A.H. (English Literature), Queen’s University – 2001
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