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Michael Colborne Taxation


Michael is a partner in the Toronto office of Thorsteinssons LLP. He received a LL.B. from the University of Manitoba and a LL.M (U.S. tax) from New York University. Michael has been called to the Bar in Ontario and British Columbia. Michael’s practice focuses on


corporate and international tax planning,


regularly advising


Canadian and foreign-based multi -national groups on a variety of


matters, including inbound and outbound investment and financing, mergers and acquisitions, divestitures, and natural resource taxation. Michael also has considerable experience in handling


tax controversy issues faced by multi-national groups (including transfer pricing issues) in Canada and a number of other countries. In this regard, Michael has appeared in the superior courts of British Columbia and Ontario, the Tax Court of Canada, the Federal Court of Appeal, the Supreme Court of Canada and before the Revenue Tribunal of the United Republic of Tanzania. Michael has a particular expertise in the taxation issues


faced by mining companies, and regularly advises a number of Canadian and foreign-based multinational mining companies. In this regard, Michael has experience structuring mining investment in Canada (including oil sands), the United States, Australia, Mexico, Scandinavia, and numerous countries in South and Central America, Africa and Central Asia. He has also been extensively involved in the recent consolidation of the natural resources sector, having advised on a number of landmark transactions. In addition to his resource clients, Michael acts for a


number of foreign-based multi-national companies. The industries in which these companies operate include real estate, aerospace and defence, paper and household products, pharmaceuticals, financial services and nuclear and hydro power. Michael speaks and writes frequently on international


and mining tax matters. He is on the editorial board of the CCH Income Tax Act and International Tax Planning (Federated Press) and is on the advisory board for the Procopio International Tax Institute of the University of San Diego. Additionally, he is a member of the Rocky Mineral Law Foundation. In 2007 Michael was named one of the leading lawyers


under 40 in Canada by Lexpert magazine. According to Chambers Global 2009 Michael “contributes heavily to the firm’s reputation in the mining industry. He is hailed for his skills in resource tax and in the foreign affiliate arena, resulting in his involvement in many cross-border and international instructions”.


Practice Areas Corporate and International Tax Planning, Tax Representation and Litigation


Select Publications Article: Payments Made in Takeover Not Deductible, Tax Court Says (co-authored with Michael McLaren) Tax Notes International, Tax Analysts (U.S.A.) Jan 24 2011 Paper: International Tax Developments: Canada Report (co-authored with Michael McLaren) International Tax Review, World Tax 2011 Guide Dec 1 2010


58 fi MONTHLY MARCH 2011 Paper: International Tax Planning: Section 93


Elections-Proposed Amendments (co-authored with Michael McLaren) Canadian Tax Journal, vol. 58, no. 2 Aug 1 2010 Paper: International Tax Developments: Canada Report (co-authored with Michael McLaren) International Tax Review, World Tax 2010 Guide Jul 31 2009 Presentation: Alternative Financing Methods: Silver Wheaton/Gold Wheaton Transactions (with Michael McLaren) Canadian Mining Law and Finance Conference: Negoti- ating Complex Markets (Vancouver) Jun 1 2009 Case Comment: Transfer Pricing-GlaxoSmithKline v. The Queen (co-authored with Michael McLaren) Canadian Tax Journal, vol. 56, no. 4 Mar 1 2009 Presentation: The Limitation on Benefits Article in the 5th Protocol to the Canada-U.S. Convention (co-authored with Shawn D. Porter, Deloitte & Touche LLP) 2008 Annual Tax Conference, Canadian Tax Foundation Nov 30 2008 Paper: International Tax Changes: Canada Report (co-authored with Michael McLaren and Matthew Williams) International Tax Review, World Tax 2009 Guide Oct 1 2008 Paper: International Tax Planning: Section 93 Elections (co- authored with Michael McLaren) Canadian Tax Journal, vol. 55, no. 4 Oct 1 2007 Paper: Tax-Deferred Domestic Corporate Reorganizations Under the Income Tax Act (Canada) International Bar Association 2001 Conference - Cancun, Mexico Oct 1 2001 Seminar: Organizing and Acquiring Canadian Businesses by U.S. Residents: A Canadian Perspective PESI Conference May 1 2001 Article: More Questions Than Answers Canadian Tax Highlights Apr 1 2001 Seminar: Advanced Tax Planning for Trusts: Exploring the Impact of the December 17, 1999 Amendments and Re- vising the Grey Areas The Canadian Institute Jun 1 2000 Article: The Shih Decision, Conventional Wisdom, and the Residence of Individuals Federated Press International Tax Planning Jan 1 2000


Contact: Michael Colborne


Tel: 416.864.9783 Fax: 416.864.1106 Toll-free: 1.888.666.9998 Email: mwcolborne@thor.ca


Leading ADVISOR 100


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