This is a photo of Angelo Discepola

Angelo
Discepola

Associate

Montréal

Contact by email at [email protected]

t. 514-397-4147

1896

Law School

University of Ottawa

Bar Admission

Québec, 2012

Angelo Discepola is an associate in our Tax Group in Montréal. His practice encompasses all aspects of domestic and international corporate income tax planning, public and private mergers and acquisitions and tax disputes. Some more notable aspects of Angelo’s practice include involvement in:

  • Private equity and venture capital fund formation and investor matters as well as developing remuneration strategies for fund principals;
  • Structuring and financing large renewable energy projects (wind and solar) both for project developers and operators; and
  • Structuring and issuing complex financial products and other capital markets matters.

Angelo received a Licentiate in Law (LLL) from the University of Ottawa in 2011 (magna cum laude). He is a member of the Canadian Bar Association and of the Young Bar Association of Montréal. He is also member of the Canadian Tax Foundation’s Young Practitioners Group and the Association de planification fiscale et financière. He has authored articles in several publications and spoken on a number of topics at various tax conferences. Angelo was called to the Québec Bar in 2012.

RECENT CLIENT ENGAGEMENTS

  • Acting for HNZ Group Inc. in connection with its acquisition by President and CEO, Don Wall, by way of plan of arrangement and the subsequent transfer of its offshore business conducted in New Zealand, Australia, the Philippines and Papua New Guinea to PHI, Inc.
  • Acting for BCE Inc. in connection with its acquisition of Alarmforce Inc. by way of plan of arrangement and the subsequent transfer of certain subscribers to TELUS Corporation
  • Acting for a Canadian fund manager and its principals in connection with the formation of an open-end global agricultural fund
  • Acting for a North American fund manager and its principals in connection with the formation of a $400 million North American clean energy private equity fund
  • Acting for BCE Inc. in connection with its acquisition of Manitoba Telecom Services Inc. by way of plan of arrangement and the subsequent transfer of certain wireless subscribers to TELUS Corporation
  • Acting for Invenergy Wind LLC in connection with its $2 billion sale of a portfolio of US and Canadian wind projects with a combined installed capacity of 930 MW to TerraForm Power
  • Acting for National Bank of Canada in the issuance of a number of structured principal protected and non-principal protected index and equity linked notes

RECENT PUBLICATIONS

  • "A Reply to the CRA’s Classification of Florida and Delaware LLLPs and LLPs as Corporations," Report of the Proceedings of the Sixty-Eighth Tax Conference, 2016 Conference Report (Toronto: Canadian Tax Foundation, 2017), 24:1-39
  • "Amendments to Québec Mining Tax Act and to Refundable Tax Credit for Resources" (March 8, 2017) Mining in the Courts Year in Review Vol. VII (Taxnet Pro’s Corporate Tax Center)
  • "The Taxation Act (Québec) Versus the Income Tax Act (Canada): A Practitioner’s Guide to Certain Key Distinctions," Report of the Proceedings of the Sixty-Seventh Tax Conference, 2015 Conference Report (Toronto: Canadian Tax Foundation, 2016), 34:1-32
  • "TCC Finds Post-Acquisition PUC Step-Up Planning to be Abusive: Univar Holdco ULC v. The Queen" (September 12, 2016) International Tax Newsletter (Taxnet Pro’s Corporate Tax Center)
  • "FAPI and Offshore Captive Insurance Arrangements" (July 6, 2015) International Tax Newsletter (Taxnet Pro’s Corporate Tax Center)
  • "Highlights of the Québec Government’s 2014-2015 Budget Relating to Businesses" (June 4, 2014) Mining & Metals Newsletter (Taxnet Pro’s Corporate Tax Center)
  • "Minister Applies GAAR to Successfully Challenge Structured Liquidation" – Descarries et al. v. The Queen, 2014 DTC 1081 (TCC) (November 27, 2014) 2229 Tax Topics (CCH – Focus on Current Cases)
  • "Duke of Westminster Carries the Day Before the Federal Court of Appeal" - The Queen v. Spruce Credit Union, 2014 DTC 5079 (FCA) (October 30, 2014) 2225 Tax Topics (CCH – Focus on Current Cases)
  • "Federal Court of Appeal Reaffirms that Minister Cannot Appeal Her Own Assessment" – The Queen v. Last 2014 DTC 5077 (FCA) (October 2, 2014) 2221 Tax Topics (CCH – Focus on Current Cases)
  • "Subsection 88(3): A policy shift?" (November 29, 2013) International Tax Newsletter (Taxnet Pro’s Corporate Tax Center)
  • "Federal Court of Appeal Upholds Denial of Deduction for Foreign Tax Under Tower Structure" – FLSmidth v. The Queen, 2013 DTC 5118 (FCA) (November 28, 2013) 2177 Tax Topics (CCH – Focus on Current Cases)
  • "Deliberate Tax Planning Is Not the same as Abusive Tax Avoidance" - Gwartz v. The Queen, 2013 DTC 1122 (TCC) (August 29, 2013) 2164 Tax Topics (CCH – Focus on Current Cases)
  • "Department of Finance Introduces New Foreign Affiliate Dumping Rules" (January 11, 2013) – McCarthy Tétrault Mining Prospects Blog

RECENT SPEAKING ENGAGEMENTS

  • "Selected Administrative and Legislative Developments" Association de planification fiscale et financière (APFF), Congrès Annuel, Montreal, October 2017
  • "Foreign Entity Classification Revisited" Canadian Tax Foundation, 68th Annual Tax Conference, Calgary, November 2016
  • "Selected Administrative and Legislative Developments" Association de planification fiscale et financière (APFF), Symposium fiscal, North Hatley, June 2016
  • "U.S. Inversion Transactions – Beyond a Change in Corporate Headquarters" Association of Corporate Counsel (Canada), Montreal, May 2016
  • "Selected Administrative and Legislative Developments" Association de planification fiscale et financière (APFF), Colloque sur la réorganisation des entreprises, Montréal, March 2016
  • "Recent Case Law and Administrative Developments" Association de planification fiscale et financière (APFF), Colloque sur les dons planifiés, Montréal, February 2016