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About Dan

Dan has a combined tax planning and tax disputes/litigation practice.

Dan practises corporate income tax law and advises on domestic and international tax planning matters, with a particular focus on M&A, corporate reorganizations, financings, debt restructurings, resource taxation and investments by private equity and pension funds. He also advises international clients looking to invest, commence or acquire business operations in Canada, especially in the oil and gas, renewable and emerging energy, technology, infrastructure and service industry sectors. He has provided structuring advice in respect of numerous complex and customized joint venture and partnership arrangements.

Dan frequently represents domestic and international clients in tax disputes with Canadian revenue authorities. His practice encompasses all stages of tax dispute resolution, from dealing with tax audits to litigating in court.

Dan is fluent in French and Serbo-Croat.

Select Experience

Examples of recent significant transactions include advising:

  • Pembina Pipeline Corporation on its acquisition of Enbridge Inc.’s joint-venture interests in Alliance Pipeline, Aux Sable and NRGreen for C$3.1-billion and its concurrent C$1.1-billion bought deal offering of subscription receipts

  • TC Energy Corporation in respect of its proposed separation into two independent, investment-grade, publicly listed companies through the spinoff of TC Energy's Liquids Pipelines business

  • Suncor Energy Inc. on its C$1.468-billion acquisition of TotalEnergies EP Canada Ltd., which holds a 31.23% working interest in the Fort Hills oil sands mining project

  • Cenovus Energy Inc. on its acquisition of warrants from Hutchinson Whampoa Europe Investments S.à r.l. and L.F. Investments S.à r.l.

  • Intact Financial Corporation on its inaugural offering of limited recourse capital notes

  • Suncor Energy Inc. on its acquisition of an additional 14.65% working interest in the Fort Hills Project from Teck Resources Limited

  • Imperial Oil Resources Limited and ExxonMobil Canada Ltd. on the disposition of their interest in XTO Energy Canada to Whitecap Resources for C$1.9-billion

  • Pembina Pipeline Corporation on its $11.4-billion joint venture with KKR & Co. to merge their western Canadian natural gas processing assets

  • Great-West Lifeco Inc. in connection with its public offerings of C$1.5-billion principal amount of 3.60% limited recourse capital notes

  • Pembina Pipeline Corporation in connection with its public offering of C$600-million aggregate principal amount of hybrid notes, the first non-chartered bank hybrid debt issuance in Canada involving the use of a special purpose trust structure

  • Hg in connection with its acquisition of Benevity Inc. alongside General Atlantic, JMI Equity and the Benevity management team

  • Jupiter Resources Ltd. in its sale to Tourmaline Oil Corp.

  • Suncor Energy Inc. on its investment in Enerkem Inc., a Canadian biofuel technology company

  • TransCanada on the sale of its 62% interest in five wind farms to Innergex

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

  • Imperial Oil Limited on its successful settlement with the Canada Revenue Agency after filing a judicial review application

  • Kinder Morgan Canada on its C$4.5-billion sale of the Trans Mountain Pipeline system and expansion project to the Government of Canada

  • ENMAX Corporation on its US$1.3-billion acquisition of Emera Inc.'s interest in Emera Maine

  • Heartland Generation Ltd., an affiliate of Energy Capital Partners, on its acquisition of Canadian Utilities Ltd.'s natural-gas and coal-electricity generation interests in Alberta, British Columbia and Ontario (acted as Canadian counsel)

  • WestJet in connection with its C$5.0-billion acquisition by Onex Corporation

  • Cona Resources Ltd. and Waterous Energy Fund on their agreement to acquire Pengrowth Energy Corporation

  • Trinidad Drilling Ltd. on its acquisition of CanElson Drilling Inc.

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

  • 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

Awards & Recognition

Dan is recognized as a leading lawyer in the following publications:

  • The Legal 500 Canada 2024 (Tax)

  • Chambers Canada: Canada's Leading Lawyers for Business 2024 (Tax)

  • The Best Lawyers in Canada 2024 (Tax)

  • Chambers Global: The World's Leading Lawyers for Business 2023 (Tax)

  • The Canadian Legal Lexpert Directory 2023 (Tax)

Professional Activities

Dan regularly presents and writes on domestic and international income tax issues. He has given presentations at the Canadian Tax Foundation and International Fiscal Association (Canada Chapter) conferences and at the Tax Executives Institute and Canadian Bar Association tax meetings. He has written for various publications, including Corporate Structures and Groups, Tax Litigation, International Tax Review and CCH. He is the Canadian contributor to the Bloomberg BNA Global Tax Guide and author of the Canada Chapter in Tax Planning for International Mergers, Acquisitions, Joint Ventures and Restructurings, published by Wolters Kluwer.

Dan is an active member of the Tax and Economic Affairs Committee of the Calgary Chamber of Commerce, the Canadian Tax Foundation, the International Fiscal Association, the Canadian Petroleum Tax Society, the Law Society of Alberta, the Law Society of Ontario, the Canadian Bar Association and the Calgary Bar Association. He previously sat on the board of directors of the Canadian Petroleum Tax Society.

Dan occasionally lectures at the University of Calgary Faculty of Law.

Publications
Professional Appearances
  • Co-presenter : Recent Transactions of Interest
    CPTS, 2023 Annual Conference, Calgary, Alberta, June 2023.
  • Co-presenter : Mandatory Disclosure Rules: Update and Select Issues
    Tax Executives Institute, Inc., 55th Annual Canadian Tax Conference, Ottawa, Ontario, May 2023.
  • Presenter : Electric Vehicles and Gas Update
    5th Annual University of Houston Law Center Denney L. Wright International Tax Conference, Houston, Texas, March 2023.
  • Co-presenter : Overview of Select Canadian Environmental Tax Initiatives
    Tax Executives Institute, Inc., Calgary, Alberta, December 2022.
  • Presenter : Overview of Canadian Legal Considerations for US Companies Expanding into the Canadian Tech Sector
    Canada-Texas Chamber of Commerce, Toronto, Ontario, June 2022.
  • Co-presenter : Doing Business in Canada
    Canada-Texas Chamber of Commerce, Houston, Texas, December 2021.
  • Co-presenter : The Capital Transition: Alternative Pools of Capital & Innovative Financing Structures
    North America Energy Capital Assembly, Houston, Texas, October 2021.
Education

Admitted to the Alberta Bar – 2009
Admitted to the Ontario Bar – 2009
LLB/BCL (With Distinction), McGill University – 2008
MA, McGill University – 2004
BA (S.F. Glass Gold Medal), University of Western Ontario – 2002

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