Doug S. Ewens
K.C.Counsel
OFFICE: Downtown
Education
- 1969 Osgoode Hall Law School, LL.B.
Admissions
- 1981 Alberta
- 1971 Ontario
Experience
Doug's primary areas of expertise are mergers and acquisitions, divestitures, reorganizations, tax-efficient financings and dispute resolution - ideally by negotiating a settlement with the CRA in the client's favour. He has rendered many opinions to clients advising on the probable impact of the general anti-avoidance rule (GAAR) on transactions or reorganizations that they are contemplating.
As well as his expertise in structuring transactions and financings for public and private enterprises, he has assisted major corporations in tax disputes, including disputes involving the general anti-avoidance rule.
Among the many transactions Doug has advised on, he was lead tax counsel for a major energy corporation in a complex asset exchange that involved a number of offshore oil and gas properties on the East Coast of Canada and in the Norwegian North Sea. He was also tax counsel in a large merger that led to the formation of a leading North American energy producer based in Calgary.
Resources
Publication
Summary of Budget 2024 Proposals
- Recognition
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Recent Media Coverage
- Quoted in “Tax Court Jurisdiction Row to Be Heard by Canada’s Highest Court”, Tax Notes, February 27, 2023
Publications
- Co-author– "Our response to the CRA's position on creditor-proofing reorganizations", Canadian Accountant, June 25, 2021
- Canadian Tax Foundation
- Canadian Tax Journal
- Canadian Petroleum Tax Society
- American Bar Association
Honours and Awards
- Recognized by The Best Lawyers in Canada® for Tax Law
- Appointed Queen’s Counsel, now known as King's Counsel - 1992
- Recipient of the Queen Elizabeth II Diamond Jubilee Medal for contributions to the Canadian Tax Foundation
- Lexpert Zenith Award in recognition of leadership through innovation
- Lexpert/American Lawyer Guide to the Leading 500 Lawyers in Canada
- Canadian Legal Lexpert Directory
- Chambers Global: The World's Leading Lawyers
- Canadian Tax Foundation Lifetime Contribution Award
- Euromoney Legal Media Group's current Guide to the World's Leading Tax Advisors
- Who's Who Legal Canada
- International Tax Review's World Tax, a guide to the world's leading tax firms
- International Tax Review named Doug one of the top 10 tax advisors who influence the choice of outside firms by in-house tax directors in North America
- Memberships
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- Canadian Tax Foundation, Past Chair & Governor
- Canadian Petroleum Tax Society
- Canadian Bar Association
- International Fiscal Association
- Teaching Roles & Speaking Engagements
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Speaking Engagements
Published numerous papers at Canadian Tax Foundation, Insight and similar tax conferences as well as in the Canadian Tax Journal. Doug's articles cover tax issues affecting partnerships, solicitor-client privilege, the section 68 "reasonableness" standard after the FCA's decision in the TransAlta case, the use of price adjustment and other adjustment clauses in agreements, reorganizations of corporate capital, the meaning of "disposition", distinguishing between a joint venture or co-ownership vs. a partnership relationship, "butterfly" reorganizations, corporate law principles constituting the foundation of income tax issues, "tracking" shares, corporate continuances, amalgamations and wind-ups, acquisitions of corporate control, "bare" trusts/nominees, oil and gas acquisitions and the use of retractable preferred shares.