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P.J. Johnston



Contact by email at [email protected]

t. +1 416-601-7923


Law School

Osgoode Hall Law School

Bar Admission

Ontario, 1984

Nigel Johnston is a partner in our Tax Group in Toronto. His practice focuses on corporate income tax issues, resource taxation (including renewable energy), providing tax advice to the investment funds industry and the creation of new financial products. He has advised numerous clients with respect to investments in offshore investment funds.


  • acting for the issuers and agents in initial public offerings of numerous TSX-listed closed-end funds including U.S. Housing Recovery Fund, Yield Advantage Convertible Debenture Fund, Star Yield Managers Class and Build America Investment Grade Bond Fund;
  • acting for Creststreet 2010 Flow-Through Limited Partnership, the first limited partnership formed to stream tax deductions to Québec resident investors and to residents in other provinces, and for the issuers and agents in respect of numerous other flow-through share offerings;
  • acting for Oxford Properties Group in its acquisition of the Metro Toronto Convention Centre from the Canada Lands Company;
  • acting for the majority shareholder of SkyPower Limited with respect to a $185 million purchase and international joint venture agreement with Canadian Solar Inc.; and
  • acting for Creststreet Power & Income Fund LP, the first public limited partnership established to develop two wind energy projects that involved an initial flow-through limited partnership offering to finance the "test wind turbine" phase of two wind farms by flowing out tax deductions to investors, a convertible debenture offering, a project financing, a subsequent equity offering and ultimately the sale of the projects and distribution of proceeds to investors.

He is a member of the Industry Regulation and Taxation Committee of the Portfolio Management Association of Canada and the Taxation Working Group of the Investment Funds Institute of Canada. He was a member of the "Informal Consultative Group on the Taxation of Collective Investment Vehicles" and of the "Pilot Group on Improving Procedures for Cross-Border Tax Claims" organized by the OECD’s Centre for Tax Policy and Administration. He is a member of the editorial board of the Canada Tax Service (Carswell). He was formerly a technical adviser to the CBA-CICA Joint Committee on taxation and has spoken and written widely on income tax matters.

Nigel received his BA (magna cum laude) in 1979 from Queen’s University and his LLB in 1982 from the Osgoode Hall Law School.