Davies

Nathan Boidman

Nat Boidman is a partner in the Taxation practice. He specializes in international taxation, with a focus on advising on cross-border mergers and acquisitions, financings and other business arrangements and relationships, including joint ventures, partnerships and business trusts. Nat also provides counsel on disputes with Canada Revenue Agency stemming from cross-border tax matters, including transfer pricing and advises on individual international tax issues, including personal investment and migration matters.

Nat has 37 years of experience advising a diverse client base on the full range of international tax issues. In addition to his private client work, Nat has served as a special advisor to the Canadian government in the landmark case of Irving Oil and in other contexts.

Prior to his career in law, Nat was a partner in an accounting firm where he specialized in taxation.

In addition to the Representative Work set out in the next section, Nat has acted for Potash Corporation of Saskatchewan with respect to a variety of international acquisitions and has acted for Sentient Global Resources Inc., in respect of a number of deals other than those mentioned below.

Representative Work

  • Acted for Potash Corporation of Saskatchewan with respect to offerings of US$500 million due 2017 and US$500 million due 2040.

  • Acted for Potash Corporation of Saskatchewan Inc. which issued US$500 million notes due May 15, 2014 and US$500 million notes due May 15, 2019.

  • Acted for GMAC LLC as it completed US$38.146 billion outstanding notes exchange and purchase offers and separate offers to exchange and purchase outstanding notes of Residential Capital, LLC.

  • Acted for Vitol Refining Group B.V. on its sale of North Atlantic Refining Limited to Harvest Energy Trust in a transaction valued at $1.6 billion.

  • Acted for The Sentient Group and a syndicate of lenders which provided a US$50-million senior secured credit facility for Ivernia Inc. and its Magellan mine in Australia.

  • Acted for Kimco Realty Corporation, a leading U.S.-based publicly-traded REIT, in connection with a partnership with Sandalwood Management Canada Co. to acquire more than 1 million square feet of retail property comprised of six shopping centers in the Province of Québec.

  • Acted for Circuit City Stores, Inc. on its acquisition of InterTAN, Inc., the operator of Radio Shack stores in Canada, in a transaction valued at approximately US$286 million to create The Source.

  • Acted for Euro-Pro Corporation and Omega Sewmac Inc. in regard to the sale of their businesses to Euro-Pro Operating LLC and the related financing.

  • Acted for Diamond Fields, as well as one of its two major shareholders, in its $4-billion sale to Inco.

  • Acted for CIT Group in its $3-billion takeover bid for Newcourt Credit Group Inc.

  • Acted for Sentient Global Resources Inc. with respect to its US$140-million divestiture of interest in Norsemont Mining Inc.

  • Acted as Canadian tax counsel to Potash Corporation of Saskatchewan with respect to offerings of US$500 million due 2015 and US$500 million due 2020.

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PUBLICATIONS

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Recognition

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Professional Affiliations

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Member, Ontario Order of Chartered Accountants, 1977

Fellow (FCA), 1999, Québec Order of Chartered Accountants, 1964

Board Memberships

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  • Past Executive Committee Member, International Fiscal Association (Netherlands)
  • Past president, Canadian Branch, International Fiscal Association
  • Council member, Canadian Branch, International Fiscal Association
  • Past member, Board of Governors, Canadian Tax Foundation
  • Past member of Joint Committee on Taxation, Canadian Bar Association and Canadian Institute of Chartered Accountants

Community Involvement

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Teaching Engagements

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Nat has lectured on the subject of taxation at the University of Sherbrooke's masters program in taxation and at McGill and Concordia Universities.

Speaking Engagements

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Nat has spoken on the subject of transfer pricing to senior members of Canada Revenue Agency. He has participated in numerous speaking engagements for the Canadian Tax Foundation, Tax Executive Institute, the International Fiscal Association's ("IFA's") Annual Congresses, the Canadian Branch of the IFA, the American Bar Association, the International Bar Association, the Federal Bar Association and numerous commercial conference organizations over the last 35 years.

Articles and Publications

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Nat has written four books on taxation and published numerous articles in leading tax journals. Nat co-edits the feature, "Canada-U.S. Tax Practice" in Tax Management International Journal and has also written the Canadian chapters for several international tax publications and services, including "The Tax Treatment of Transfer Pricing", a loose leaf service published by the International Bureau of Fiscal Documentation (Amsterdam) and "Transfer Pricing: Foreign Rules and Practice Outside of Europe (Foreign Income Portfolios)" published by Tax Management, Washington.  Nat organized, for Tax Notes International, a 14-installment ongoing feature involving 20 prominent and leading international tax lawyers, with regard to international M&A.

Nathan Boidman
Nathan Boidman
Partner
Office:
Montréal
Tel:
514.841.6409
Email:
nboidman@dwpv.com
Bar Admissions:

Québec, 1981

Education:

McGill University, B.C.L./LL.B., 1980

McGill University, B.Comm., 1962