A recognized leader in corporate and cross-border tax law, Jeff helps clients navigate complex transactions and reorganizations
Jeff is a Partner in the Firm’s National Tax Group in Toronto with a practice focusing on domestic and cross-border mergers & acquisitions and reorganizations. He develops success-driven tax planning structures.
Jeff is an experienced senior tax practitioner, renowned for developing innovative tax planning structures for multi-nationals and Canada’s leading financial institutions. He has extensive experience guiding clients, including a variety of pension plans, through complex domestic and cross-border M&A transactions, reorganizations and investments. He is one of the leading tax advisors in Canada in the area of corporate reorganizations and butterfly transactions.
Jeff frequently acts for clients across a range of industry groups. Jeff teaches butterfly transactions at the Tax Law for Lawyers course and, for several years, lectured on capital gains stripping and divisive reorganizations at the In-Depth Tax Course for CPA Canada. He is a member of the editorial board for the International Tax Planning journal, and a contributor to the Canadian Tax Journal.
Jeff has advised on the Canadian tax aspects of a variety of deals and reorganizations, including the following transactions:
- UnitedHealth Group, in connection with its acquisition of Catamaran Corporation for approximately US$12.8 billion;
- Burger King Worldwide, in connection with its acquisition of Tim Hortons Inc. for approximately US$12.5 billion, the U.S. tax inversion of Burger King under Restaurant Brands International Inc., the related financing, which involved a US$3 billion preferred equity investment from Berkshire Hathaway Inc., a secured US$7.25 billion credit facility and a private placement of US$2.25 billion of second lien secured notes, and an associated tender offer for Tim Hortons' outstanding US$1.2 billion of debt securities;
- Vistra Energy, in connection with its acquisition of assets from Crius Energy Trust;
- Baxter International Inc., in connection with its spin-off of Baxalta Incorporated;
- GlaxoSmithKline, in connection with its joint venture with Pfizer to combine their consumer healthcare businesses; and
- Chrysler Canada, in respect of its restructuring.
AWARDS & RANKINGS
The Douglas J. Sherbaniuk Distinguished Writing Award in respect of the paper cited as Jeff Oldewening, Rachel A. Gold and Chris Sheridan, “Statutory Ratification” (2016) 64:1 Canadian Tax Journal 293-325. The Canadian Tax Foundation confers this honour for the best writing undertaken for the Canadian Tax Foundation every year.
