Paul K. Tamaki, Lawyer
Contributing Editor, Conference Chair
Federated Press Contributions
| Contributing Editor, Business Vehicles (BV) 1994– |
| Contributing Editor, Corporate Finance (CF) 1993– |
| Chair, Tax-Effective Transactions Session, Super Transactions Conference, Toronto, May 22-23, 1996 |
| "Withholding Tax Proposals Facilitates Restructuring of Existing Exempt Loans" (1994) 2 CF 109 |
| "Lease Financing – When Is a Lease a ‘True Lease'?" (1994) 2 CF 147 |
| "Revenue Canada's ‘Look-Through' Approach to Partnerships" (1994) 1 BV 3 |
| "Assignment of Partnership Interests" (1994) 1 BV 18 |
| "Revenue Canada Addresses a Timing Issue Under Section 53(1)(e) of the Income Tax Act" (1994) 1 BV 38 |
| "Sales of Accounts Receivable in Securitizations – Income in Character" (1995) 3 CF 190 |
| "Continental Bank of Canada Versus The Queen" (1995) 3 CF 196 |
| "Expenses Incurred by a Corporation Relating to Takeover Bids" (1995) 3 CF 219 |
| "Interpretation of Bulletin IT-448 Creates Controversy over Restructuring of Debts" (1995) 3 CF 243 |
| "The Use of Partnership Rollovers to Effect a Transfer of Assets" (1995) 1 BV 54 |
| "The New Definition of Taxable Canadian Property Affects Reorganizations of Canadian Public Corporations" (1996) 4 CF 252 |
| "What Is the Scope of Paragraph 214(15)(b)?" (1996) 4 CF 254 |
| "Taxable Preferred Shares – Loss of Grandfathering" (1996) 4 CF 303 |
| "Focus on Issuer Bids" (1996) 4 CF 318 |
| "More Timing Problems in Calculating the ACB of a Partnership Interest" (1996) 2 BV 81 |
| "The Use of a Partner's Assets by a Partnership" (1996) 2 BV 94 |
| "Partnerships and the New Tax Shelter Rules" (1996) 2 BV 102 |
| "Focus on Issuer Bids" (1996) 4 CF 318 |
| "What Is the Scope of Paragraph 214(15)(b)?" (1996) 4 CF 254 |
| "Tax Issues Relating to Employees of a Partnership" (1997) 3 BV 128 |
| "Characterizing Leases for Tax Purposes" (1997) 5 CF 390 |
| "Shell Canada Limited v. The Queen" (1997) 5 CF 443 |
| "The Validity of Partnerships in Tax-Motivated Transactions: The Continental Bank Leasing Case" (1998) 4 BV 215 |
| "Foreign Tax Credits and Hybrid Entities Used in Cross-Border Transactions" (1998) 6 CF 530 |
| "More News on the Capital Tax Base" (1999) 7 CFI 598 |
| "Wildenberg Holdings Ltd. v. The Minister of Revenue" (1999) 7 CFI 600 |
| "Foreign Currency Translation: Today's Labyrinth" (1999) 7 CF 654 |
| "Book4golf: Convertible Share Financing" (2000) 8 CF 731 |
| "Changes to Taxation of Non-Controlling Investments in Foreign Investment Entities — Investor Beware" (2000) 6 BV 308 |
| "Amendments to Loans and the Five-Year Test Under Subparagraph 212(1)(b)(vii)" (2000) 8 CF 761 |
| "LCT and Off Balance Sheet Financing" (2001) 9 CF 807 |
| "Partnership Reporting Requirements Under the Income Tax Act" (2001) 7 BV 325 |
| "The CCRA's Finding on the Status of Delaware Partnerships for Canadian Tax Purposes" (2001) 7 BV 331 |
| "The Use of Partnerships in Tax-Motivated Transactions" (2001) 7 BV 352 |
Biography
| Born 11 May 1947 |
| Educated McGill University B.Eng. 1969; University of Toronto LL.B. 1975 |
| Partner, Blake, Cassels & Graydon LLP 1983– |
| Associate with present firm 1977-83 |
| Called to the Bar of Ontario 1977 |
| Articled with present firm 1976-77 |
| Member, Professional Engineers Ontario, Canadian Tax Foundation, International Fiscal Association, Metropolitan Toronto Board of Trade (Tax Committee), Canadian Bar Association-Ontario (Former member of the Legislative Subcommittee of the Tax Section) |
| Author, numerous articles in the area of taxation |
Practice Description
| Mr. Tamaki practices in all areas of taxation law, with particular emphasis on corporate tax planning, corporate finance, international transactions, mergers and acquisitions, transfer pricing, and representing clients in administrative tax appeals, and representations to governments. |
Address
| Blake, Cassels & Graydon LLP |
| 199 Bay Street, Suite 2800 |
| Box 25, Commerce Court West |
| Toronto, Ontario M5L 1A9 |
| Telephone: (416) 863-2400 |
| Telecopier: (416) 863-2653 |
| E-mail: paul.tamaki@blakes.com |
| Web: www.blakes.ca |
Entry updated August 2000