Edward is a Partner in the National Tax Group in the Calgary office. His practice focuses on corporate and international tax planning, regularly advising Canadian and foreign-based multi-national groups on a variety of matters, including inbound and outbound investment and financing, mergers and acquisitions, divestitures, and natural resource taxation.
His tax practice also includes the settlement of tax disputes, including GAAR (General Anti-Avoidance Rule) assessments with the Canada Revenue Agency, including Canadian Competent Authority, and he has acted as counsel in leading tax cases before all levels of courts.
Edward served on Executive Interchange as a special adviser to the Tax Policy Branch of the Department of Finance on matters related to resource tax and corporate reorganizations.
Areas of Expertise
Representative Work
- Canadian Natural Resources Limited
Canadian Natural Resources Limited in the restructuring of the North West Redwater Refinery
- Golder Associates Corporation
Golder Associates Corporation in its $1.5 billion acquisition by WSP
- Suncor Energy Inc.
Suncor Energy Inc. in its takeover of day-to-day operations at Syncrude oil sands mining joint venture
- KKR
Acting for KKR and AIMCo in their joint acquisition of a combined 65% equity interest from TC Energy in the $6.8B Coastal GasLink Pipeline Project
- SemCAMS Midstream ULC
SemCAMS Midstream in its $1.3 billion agreement with Keyera to build Canadian Liquids Pipeline System
- ConocoPhillips
ConocoPhillips in the sale of its interest in the Foster Creek Christina Lake (FCCL) oil sands partnership, as well as the majority of its western Canada Deep Basin gas assets, to Cenovus for total proceeds of C $17.7 billion.
- BP Canada Energy Company
BP Canada Energy Company in BP Canada Energy Company v. MNR (2017 FCA 61)
- Canadian Natural Resources Limited
Canadian Natural Resources Limited in connection with the sale of certain royalty interests to PrairieSky Royalty Ltd for $1.8 billion
- Suncor Energy Inc. on Canadian tax aspects of its agreement to sell its conventional natural gas business to Qatar Petroleum International and Centrica PLC for $1 billion
- Chevron Canada on the Canadian tax aspects of its acquisition of a 50% interest in the Kitimat LNG Terminal project and the Pacific Trails Pipeline from Encana Corp. and EOG Resources
- Kinder Morgan Energy Partners on the Canadian tax aspects of the sale of their interest in the Express-Platte Pipeline System, which was acquired by Spectra Energy Corp. for $1.49 billion
- ConocoPhillips on Canadian aspects of the $35 billion spin-off of its global downstream business by way of a tax free distribution of Phillips 66
- Pembina Pipeline Income Fund in connection with its conversion from an income trust to a corporation
- The underwriters in connection with the $149.5 million initial public offering of trust units by Eagle Energy Trust, an oil and gas energy trust with production located in the United States
- ConocoPhillips on its $4.7 billion disposition of a nine per cent interest in Syncrude to Sinopec
- Hunt Oil Company on the $525 million sale of its Canadian assets to Harvest Operations Corp
- Nexen Marketing in the disposition of its North American natural gas marketing business to J. Aron & Company, a subsidiary of The Goldman Sachs Group, Inc
- Suncor Energy Inc. on its strategic oil sands alliance with Total E&P encompassing the Fort Hills and Joslyn oil sands mining projects and the Voyageur upgrader
- Suncor Energy Inc. on its $43 billion merger with Petro-Canada
- Kinder Morgan Energy Partners, L.P. in its acquisition of the Cochin Pipeline System, the Express Pipeline System and the Trans Mountain pipeline system
- Kinder Morgan, Inc. on its disposition of Terasen Inc. to Fortis Inc
Canadian Natural Resources Limited in the restructuring of the North West Redwater Refinery
Golder Associates Corporation in its $1.5 billion acquisition by WSP
Suncor Energy Inc. in its takeover of day-to-day operations at Syncrude oil sands mining joint venture
Acting for KKR and AIMCo in their joint acquisition of a combined 65% equity interest from TC Energy in the $6.8B Coastal GasLink Pipeline Project
SemCAMS Midstream in its $1.3 billion agreement with Keyera to build Canadian Liquids Pipeline System
- ConocoPhillips
ConocoPhillips in the sale of its interest in the Foster Creek Christina Lake (FCCL) oil sands partnership, as well as the majority of its western Canada Deep Basin gas assets, to Cenovus for total proceeds of C $17.7 billion.
- BP Canada Energy Company
BP Canada Energy Company in BP Canada Energy Company v. MNR (2017 FCA 61)
- Canadian Natural Resources Limited
Canadian Natural Resources Limited in connection with the sale of certain royalty interests to PrairieSky Royalty Ltd for $1.8 billion
- Suncor Energy Inc. on Canadian tax aspects of its agreement to sell its conventional natural gas business to Qatar Petroleum International and Centrica PLC for $1 billion
- Chevron Canada on the Canadian tax aspects of its acquisition of a 50% interest in the Kitimat LNG Terminal project and the Pacific Trails Pipeline from Encana Corp. and EOG Resources
- Kinder Morgan Energy Partners on the Canadian tax aspects of the sale of their interest in the Express-Platte Pipeline System, which was acquired by Spectra Energy Corp. for $1.49 billion
- ConocoPhillips on Canadian aspects of the $35 billion spin-off of its global downstream business by way of a tax free distribution of Phillips 66
- Pembina Pipeline Income Fund in connection with its conversion from an income trust to a corporation
- The underwriters in connection with the $149.5 million initial public offering of trust units by Eagle Energy Trust, an oil and gas energy trust with production located in the United States
- ConocoPhillips on its $4.7 billion disposition of a nine per cent interest in Syncrude to Sinopec
- Hunt Oil Company on the $525 million sale of its Canadian assets to Harvest Operations Corp
- Nexen Marketing in the disposition of its North American natural gas marketing business to J. Aron & Company, a subsidiary of The Goldman Sachs Group, Inc
- Suncor Energy Inc. on its strategic oil sands alliance with Total E&P encompassing the Fort Hills and Joslyn oil sands mining projects and the Voyageur upgrader
- Suncor Energy Inc. on its $43 billion merger with Petro-Canada
- Kinder Morgan Energy Partners, L.P. in its acquisition of the Cochin Pipeline System, the Express Pipeline System and the Trans Mountain pipeline system
- Kinder Morgan, Inc. on its disposition of Terasen Inc. to Fortis Inc
Latest Insights
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Osler Update Apr 30, 2024
Transfer Pricing 2024: Law and Practice
The federal government has plans to update the rules that govern transfer pricing — the pricing one branch or division or group of a company...
Read more
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Webinar Sep 5, 2023
Canadian Tax Law Insights: Clean Energy Measures – Updates and Draft Legislation
Join members of our Tax and Energy teams for an in-depth discussion of the clean energy measures in this legislation package and how they might...
Read more
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Osler Update Aug 9, 2023
Canada releases long-awaited draft legislation for tax credits supporting the clean energy sector
On August 4, 2023, the Canadian federal government released long-awaited draft tax legislation for the Clean Technology Investment Tax Credit, labour...
Read more
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Webinar Jun 13, 2023
Canadian Tax Law Insights: Managing Tax Audits to Prevent and Resolve Disputes with the CRA – Part I
Members of Osler’s Tax Group provide guidance and best practices for preventing and resolving tax disputes earlier, and more effectively, in light...
Read more
Awards and Recognition
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Chambers Canada: Canada’s Leading Lawyers for Business: Recognized in Tax; Tax: Litigation
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Chambers Global: The World’s Leading Lawyers for Business: Recognized in Tax
- “…assists clients with tax planning advice both within Canada and internationally. His practice is wide-ranging, and includes financings, divestitures, reorganisations and M&A.”
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The Canadian Legal Lexpert Directory: Recognized in Corporate Tax; Litigation – Corporate Tax; Alberta’s best corporate tax lawyers in 2021
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Best Lawyers in Canada: Recognized in Tax Law
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Legal 500: Recognized as a recommended Lawyer in Tax
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International Tax Review: Recognized in Tax Controversy, as a Highly Regarded lawyer and as a Tax Leader
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Tax Directors Handbook: Recognized in Tax Directors Handbook
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Who’s Who Legal: Recognized in Corporate Tax – Controversy; Corporate Tax – Advisory; Canada – Corporate Tax
Media Mentions
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Osler News Aug 25, 2023
Osler recognized as a Tier 1 firm in ITR’s World Tax Guide 2024
Osler is proud to once again be recognized as a Tier 1 firm in the 2024 edition of the International Tax Review’s World Tax guide. Additionally, 19...
Read more -
Osler News Apr 19, 2023
42 Osler lawyers recognized by Lexpert as leaders in Finance and M&A
Osler is proud to announce 42 of our lawyers have been recognized as leaders in the Lexpert Special Edition: Finance and M&A 2023.
Read more -
Osler News Oct 4, 2021
Osler recognized as a Tier 1 firm in ITR’s World Tax Guide 2022
Osler has maintained its Tier 1 rankings in ITR’s World Tax Guide with 18 lawyers recognized as leaders in their field.
Read more -
Osler News Sep 22, 2021
Osler named ‘Canada Tax Firm of the Year’ for the second consecutive year at the ITR Americas Tax Awards 2021
Osler is proud to be recognized as “Canada Tax Firm of the Year” for the second consecutive year by ITR Americas Tax Awards.
Read more
Speaking and Writing
Speaking Engagements
Canadian Tax Law Insights: Clean Energy Measures – Updates and Draft Legislation
Read moreCanadian Tax Law Insights: Managing Tax Audits to Prevent and Resolve Disputes with the CRA – Part I
Read moreCanadian Tax Law Insights: Managing tax audits to prevent and resolve disputes with the CRA – Part 2
Read moreCanadian Tax Law Insights: Clean energy tax incentives in the 2023 federal budget
Read moreSupreme Court guidance on Canada’s international tax regime: Implications of Alta Energy and Loblaw
Read morePractical Tips for Managing Tax Risk at the Transaction, Audit and Objection Stages
Read morePublished Work
- Transfer Pricing 2024 – Canada, Global Practice Guides, Chambers and Partners, April 11, 2024 (with Amanda Heale, Mark Brender and Kaitlin Gray).
- Current Cases Including GAAR and Aggressive Tax Planning Developments, November 2, 2011, Canadian Petroleum Tax Society, 2011 Fall Lecture Series (with Carrie Aiken).
- Inbound Financing and Investments, September 7-8, 2011, Taxation of Corporate Finance and Financial Structures, Acumen Information Services (with Carrie Aiken).
Credentials
Education
- University of Calgary, LL.B. (Gold Medallist)
- University of Calgary, B.A. (Gold Medallist)
Languages
- English
Professional Affiliations
- International Fiscal Association
- Canadian Tax Foundation
- Canadian Petroleum Tax Society
- Law Society of Alberta
- Law Society of Ontario
