Paul Carenza

Paul Carenza is a partner in the Tax Group. His practice is focused on providing income and commodity tax advice in domestic and cross-border corporate acquisitions, reorganizations and financings.

Paul provides expert advice to clients on executive compensation matters, including compensation plan design and foreign assignments. He also has a successful track record of representing taxpayers in disputes with the tax authorities.

Representative examples of Paul’s experience include:

• Advising a European investment fund in its acquisition of an interest in the Canadian hi-technology sector
• Advising US service providers on entering the Canadian marketplace
• Advising a Canadian financial institution on the implementation of an employee share purchase plan
• Advising a US multinational when extending its compensation plans to employees of Canadian subsidiaries
• Advising public and private companies on the implementation of stock option plans, restricted stock unit plans and deferred share unit plans
• Representing individuals and corporations in voluntary disclosures with the Canada Revenue Agency
• Representing participants in the construction industry with respect to RST and HST transition matters
• Advising clients in the not-for-profit sector

Recent transactions in which Paul has been involved include:

• Acting for Avion Gold Corporation in its acquisition by Endeavour Mining for $389 million
• Representing Allied Nevada Gold Corp. in a senior note offering valued at $400.4 million
• Acting for LSF REIT Holdings S.à.r.l., an affiliate of Lone Star Real Estate Fund (U.S.) L.P, in the sale of its $1 billion German real estate portfolio to Dundee International REIT
• Acting for New Gold Inc. in a $300 million offering
• Representing IC Potash Corp. in the completion of its strategic investment and off-take agreement with Yara International ASA
• Acting as Canadian counsel to Alexion Pharmaceuticals, Inc. in its approximately $1.08 billion acquisition of Enobia Pharma Corp.

Paul works with several other practice groups within the firm to offer our clients tax strategies to facilitate successful business solutions.

Paul provides services in both official languages.

Biographie en français

Publications and Resources

• “Incentive Compensation for Small and Medium-Sized Private Companies”, Ontario Tax Conference, Canadian Tax Foundation, Toronto, 2012
• “Imperial Tobacco: Stock Option Plans and Cash-out Payments”, Taxation of Executive Compensation and Retirement, Volume 22, No. 5, Federated Press
• "Changes to the Taxation of Stock Options", Canadian Payroll Reporter, December, 2010
• "Say-on-Pay, Clawbacks and Canadian Income Tax", Taxation of Executive Compensation and Retirement, Volume 21, No. 1, Federated Press
• "Update On ULC's - Rising From The Ashes?," TaxnetPRO, December 2009
• "Directors' Liability for Taxes: The Importance of Being Diligent," Corporate Liability, Federated Press, 2009
• "The ABCs of Cashless Exercise Methods," CMA Magazine, October 2005
• "Avoidance Transaction is not a Dirty Word (or a Series of Dirty Words)!" Taxation Law Section Newsletter, Vol. 14, No. 1, Ontario Bar Association, August 2003
• "Competent Authority Agreements?" Canadian Tax Highlights, Vol. 10, No. 10, Canadian Tax Foundation, 2002
• "Fredette and Rousseau-Houle: Has CP Been Derailed?" Taxation Law Section Newsletter, Vol. 12, No. 1, Ontario Bar Association, August 2001
• "GST Reg Ultra Vires?" Canadian Tax Highlights, Vol. 8, No. 11, Canadian Tax Foundation, November 2000
• "Business Succession for the Entrepreneurial Client," Institute of Chartered Accountants of British Columbia, July 2000

Presentations

• Speaker, "Incentive Compensation for Small and Medium-Sized Private Companies”, Ontario Tax Conference, Canadian Tax Foundation, Toronto, 2012
• Speaker, "10th Taxation of Executive Compensation and Retirement Course", Federated Press, Toronto, 2012
• Co-Chair and Speaker, "2nd Understanding Canada-U.S. Taxation Course", Federated Press, Toronto, 2012
• Speaker, "4th International Joint Ventures Course", Federated Press, Toronto, 2011
• Speaker, "9th Taxation of Executive Compensation and Retirement Course", Federated Press, Toronto, 2011
• Speaker, "Understanding Canada-U.S. Taxation Course", Federated Press, Toronto, 2011
• Speaker, "8th Taxation of Executive Compensation and Retirement Course", Federated Press, Toronto, 2010
• Speaker, "4th Taxation of Inbound Investment Course", Federated Press, Toronto, 2010
• Speaker, “7th Taxation of Executive Compensation and Retirement Course”, Federated Press, Toronto, 2009
• Speaker, "Commercialization of Innovative Research: Implementing Solutions That Work for Canada," IP Osgoode, Toronto, 2009
• Chair, "Taxation Issues in Acquisition Transactions - A Practical Review," Ontario Bar Association, Toronto, 2008
• Co-Chair, "Non-Resident Tax Primer for the Generalist," Ontario Bar Association, Toronto, 2008
• Chair, "Happy Birthday GAAR: The Tax Court Decisions since Canada Trustco and Matthew," Ontario Bar Association, Toronto, 2007
• Co-Presenter, "Taxable Preferred Shares Workshop," Fifty-Eighth Annual Conference, Canadian Tax Foundation, Toronto, 2006
• Guest Lecturer, "Butterfly Transactions," University of Western Ontario Law School, 2005
• Guest Lecturer, "Information Technology and Internet Law Course," University of British Columbia Law School, 2003-2004

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