Practice Expertise

  • Mining
  • Taxation
  • Venture Capital
  •  

Areas of Practice

  • Mining
  • Taxation
  • Venture Capital
  •  

Profile

Len's practice focuses on taxation including both income and commodity taxation. He advises both private and public clients primarily on transactional and corporate reorganization matters. A large part of Len's practice involves working for clients that carry on business outside of Canada. For these clients, Len designs tax efficient structures including utilizing appropriate vehicles and transfer pricing methodologies. He also provides advice to Canadian pension plans in connection with their acquisitions and divestments both inside and outside of Canada.

Bar Admissions
British Columbia (1991)
Northwest Territories (2002)

Education
University of Manitoba (B.A., 1984)
University of Toronto (LL.B., 1989)

Areas of Practice

  • Mining
  • Taxation
  • Venture Capital

Professional Career

Significant Accomplishments
Advisor to major western Canadian public sector pension plans and government investment entities with respect to investments in various domestic and international private equity funds and direct investments

Advisor to sponsors of various Western Canada based private equity and venture capital funds in relation to the tax structuring and formation of those funds

Advisor to Canadian listed Australian mining corporations in respect of their worldwide mining acquisitions

Advisor to both issuing corporations and underwriters with respect to various public offering of securities

Structure and advise in connection with public company spin-outs and spin-offs

Structure run-of-the-river Hydro-electric project

Advisor to industry in respect of British Columbia's new carbon tax

Tax advisor to a recreational property developer in connection with waterfront developments

Drafted and structured deferred compensation arrangements, including stock option and share appreciation rights for non-resident clients acquiring Canadian businesses


Professional Associations
*International Fiscal Association, Member
*Canadian Tax Foundation, Member and Former Governor
*Canadian Bar Association (B.C. Branch), Tax Subsection, former Chair
*BCIT Management Studies Department, Former Sessional Lecturer

Recognition and Ranking
*Best Lawyers in Canada: recognized for tax law

Seminars/ Presentation
"Canada - doing business, transaction taxes, cross-border transactions", Seattle Chapter of the TEI and the University of Washington School of Law 2013 Tax Forum (February 22, 2013), Speaker

"Overview of Inbound/Outbound Transactions from a Canadian Perspective", International Tax Conference, Washington Society of Certified Professional Accountants (WSCPA), Seattle, WA (April 27, 2012), Speaker

"Inbound to Canada", International Taxation Seminar, Sterling Education Services, Inc., Seattle, WA, (February 17, 2012), Speaker

"Outbound to Canada: Recent Developments", International Tax Conference, Washington Society of Certified Professional Accountants (WSCPA), Seattle, WA (May 4, 2011), Speaker

British Columbia Tax Conference (September 2009), Speaker

Cross Border Tax Issues in Alberta (December 9, 2008), Speaker

"Business Expansion into Canada Recent Developments”, Oregon and Washington Tax Institute co-sponsored by the Oregon State Bar Taxation Section, Washington State Bar Association Law Section, OSB CLE Seminars, and WSBA CLE, Seattle Washington (May 1-2, 2008), Speaker

"Tax Equalization Policies and Benefits affecting today's Global Executives”, Inter-Pacific Bar Association 18th Annual Conference, Los Angeles, California (April 28-30, 2008), Speaker

"Kettle Inc. comes to Canada distributing kettles in Canada”, Inter-Pacific Bar Association 17th Annual Conference, Beijing, China (April 20-23, 2007), Speaker

"Tax issues arising from Cross-Border Businesses”, International Taxation Seminar, Seattle Washington (February 8, 2007), Speaker

"Sift Update Taxation of Income Funds”, British Columbia Tax Conference Report, Canadian Tax Foundation (2007), Speaker



Articles

"2012 Federal Budget: Changes to the thin-capitalization rules" (April 10, 2012), Co-Author

Canadian Tax Rates, Not Quite a Tax Haven (March 7, 2012), Author

"Proposed Amendments to Section 892 Regulations" (November 2, 2011), Co-Author

"Overview of the Differences between the U.S. and Canadian Entity Classification Systems" (October 6, 2011), Author

"US Canada Cross-Border Tax: Getting out of Canada" (June 1, 2011), Author

"US Canada Cross-Border Tax: When to Worry About Canada" (March 23, 2011), Author

Federal Budget 2010 Taxation Measures of Interest to Technology Companies, Private Equity and Venture Capital (March 17, 2010)

Introduction of ULC Legislation in Alberta (June 15, 2005), Author

The Benefits of Using an Unlimited Liability Company (April 29, 2005), Author

Tax Issues - Canadian Operations (July 11, 2002), Author

Equity-Based Compensation for Canadian Employees (May 2, 2002), Author

Corporate-Owned Life Insurance: Where Are We Now? (April 17, 2002), Author

“Section 80: An Update”, British Columbia Tax Conference Report, Canadian Tax Foundation (2002), Author

“Sale of a Business - Purchaser and Vendor Issues”, BC Tax Conference Report, Canadian Tax Foundation (1999), Author

“Canadian Inbound Investment with Limited Liability Companies - A Trap for the Unwary”, U.S. publication Tax Notes International (October 26, 1998), Author

Blogs

North of 60 Blog

Our North of 60 Blog provides commentary on current legal trends and developments, and legislative updates affecting businesses in Northern Canada.

Pensions and Employee Benefits Law Blog

Lawson Lundell's Pension and Employee Benefits Law Blog provides updates on the most recent legal developments impacting pension and employee benefit plans. We cover a range of topics, including recent case law and changes to relevant provincial and federal legislation.

Privacy & Data Management Blog

This blog is authored by members of the Privacy & Data Management Department. We follow new and interesting issues emerging in the legal and business communities. We follow emerging issues, legal developments, and new technology as they impact privacy and data management. We will focus on how organizations can protect, manage and innovate with information considering the various risks, regulatory and governance requirements.

The Business Law Blog

This blog is authored by members of the Litigation and Dispute Resolution Department. We intend to follow new and interesting issues emerging in the legal and business communities. The wide range of experience among the members of our litigation group will provide a diverse and insightful examination of current legal trends and topics. Our goal is to provide a source of valuable information and insight on a wide variety of matters for our readers.

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