This is a photo of Photo of Robert W. Nearing

W. Nearing



Contact by email at [email protected]

t. +1 403-260-3678


Law School

University of New Brunswick

Bar Admission

Alberta, 2005
British Columbia, 2002
Nova Scotia, 2002

Technically proficient and extremely knowledgeable of tax rules and the assessing practices of the Canada Revenue Agency, Robert helps clients avoid and resolve tax issues in a practical, timely and efficient manner.

Robert is the lead partner in the firm’s Tax Group in Calgary. His practice focuses primarily on the tax aspects of innovative financing structures, mergers, acquisitions, private equity transactions and complicated reorganizations, including complex cross-border transactions and intra-group restructuring. He also advises on the structuring of derivative instruments, transfer pricing matters and disputes with domestic and international tax authorities.

A lateral thinker, Robert is adept at formulating creative solutions to address or avoid issues that inevitably arise during the tax structuring process. With his intimate knowledge of the Income Tax Act (Canada), case law and the assessing practices of the Canada Revenue Agency, Robert is able to quickly and efficiently formulate strategies to meet each client’s unique need.

Clients doing business in the U.S. and U.S. businesses expanding into Canada appreciate Robert’s thorough understanding of the Income Tax Act (Canada) as it relates to cross-border transactions and international tax minimization. This knowledge makes Robert a valued facilitator of cross-border transactions.

Some of the notable files Robert has advised on are:

  • Newcrest Mining Ltd.’s acquisition of a 70% joint venture interest in the Red Chris copper and gold mine in British Columbia from Imperial Metals Corp. for US$804 million,
  • Enbridge Inc.’s acquisition of Spectra Energy Partners, LP for C$4.3 billion,
  • HSBC Bank Canada on the issuance of US$750 million covered bonds,
  • Enbridge Inc.’s acquisition of Enbridge Income Fund Holdings Inc. for C$4.7 billion,
  • BCE Inc.’s acquisition of Manitoba Telecom Services Inc. for C$3.9 billion,
  • BCE Inc.’s acquisition of AlarmForce Industries Inc. for C$182 million,
  • Shell’s $11.1 billion divestiture of oil sands interests in Canada,
  • International Paper Co.’s US$2.2 billion acquisition of Weyerhaeuser Co.’s pulp business,
  • Energy Investments Global Ltd.’s C$1.7 billion takeover of Heritage Oil PLC, and
  • Enbridge Inc.’s acquisition of Spectra Energy Corp. for C$37 billion.

Presentations & Publications

Robert is a frequent speaker and contributor to tax-related events and publications. Some of his recent involvements include:

  • Co-author of Carswell’s Canada Tax Service Foreign Affiliates Guide.
  • Presented on the anti-treaty shopping proposal to the Tax Executive Institute.
  • Presented at the “Current Cases” plenary session of the 64th Annual Tax Conference hosted by the Canadian Tax Foundation.
  • Presented on outbound investment and foreign exchange issues to the Canadian Electricity Association.
  • Presented on foreign affiliate reorganizations to the Canadian Petroleum Tax Society, as well as other seminars hosted by the Tax Executive Institute, the Canadian Bar Association and the Pacific Business and Law Institute.
  • Published in the Canadian Petroleum Tax Journal, Canadian Tax Highlights, Tax Litigation and Lexpert.

Robert is a member of the International Fiscal Association and the International Fiscal Association Canadian Council, the Canadian Bar Association (Tax Law Section) and the Canadian Tax Foundation, and he is a former member of the Canadian Bar Association/Chartered Professional Accountants of Canada Joint Committee on Taxation.