Lorne Saltman

Executive Summary

Lorne Saltman is a partner at Gardiner Roberts and Head of the firm’s Tax Group. He has extensive experience across a wide range of tax matters, with a practice that spans both domestic and international tax planning. Lorne regularly advises high-net-worth individuals and businesses on wealth preservation, cross-border acquisitions and financings, corporate reorganizations, real estate ventures, and the establishment of offshore trusts and private foundations.

Lorne also has a strong track record in resolving disputes with tax authorities at both the federal and provincial levels, including representing clients in tax litigation. He is valued for his strategic approach and his ability to navigate complex tax issues efficiently and effectively.

In addition, Lorne brings deep experience in domestic and international tax and estate planning for entrepreneurs and corporate executives. His work includes estate freezes of private corporations, the establishment and administration of family and discretionary trusts, and the creation of private charitable foundations, all tailored to support long-term planning and succession goals.

Expertise

• Tax and Estate Planning

Representative Work

• Advised Canadian real estate developer on structure of $40 million joint venture with development partners;
• Provided legal advice on transfer pricing policies of Canadian‑based telecommunications corporation with significant pension plan deficit in foreign affiliate;
• Established captive insurance company in Barbados for a Canadian‑based real estate development company with U.S. operations;
• Advised a Caribbean country on its tax treaty negotiations;
• Advised an estate freeze trust/corporate structure for partners in a new Canadian investment bank;
• Advised a successful Canadian interior decorator on his acquisition of U.S. real property interests;
• Advised an ultra‑high‑net‑worth Canadian resident on a departure tax plan involving a private charitable foundation and life insurance;
• Advised a terminally‑ill doctor on reorganizing his affairs, including share and debt capital reorganizations, settling an Alter Ego Trust and Principal Residence Trust, and revising Wills to include testamentary trusts;
• Established a Barbados‑based trust and corporate structure to protect business and investment assets of Venezuelan families;
• Negotiated successfully with the Canada Revenue Agency in connection with voluntary disclosures of unreported income for an individual with investment income from a foreign jurisdiction with a blocked currency, for a computer software company whose managing director appropriated assets and funds from the company, and for a Canadian‑based multinational corporate group with defective international tax planning;
• Negotiated successfully with the Canada Revenue Agency in the settlement of a tax claim exceeding $6 million against a trio of world-famous entertainers who used a complex but compliant tax structure in connection with performances in Canada;
• Worked with litigation counsel to obtain Rectification Order to prevent realization of unintended $24 million capital gain in defective corporate reorganization;
• Worked with high-net-worth families to develop a governance structure and succession plan;
• Worked with high-net-worth clients immigrating to Canada to establish tax-free “Granny Trusts” and tax-effective corporate structures