Lorne Saltman

Executive Summary

Lorne Saltman is a Partner with Gardiner Roberts LLP. He has extensive experience in diverse areas of tax practice, including in-depth experience on both the international and domestic levels involving wealth preservation for high-net worth clients, cross-border acquisitions and financings, corporate reorganizations, real estate ventures, and the establishment of offshore trusts and private foundations.

He has a successful track record in resolving disputes with tax authorities at both the federal and provincial levels, including some experience in tax litigation.

Lorne has in-depth experience in tax and estate planning, both domestic and international, for entrepreneurs as well as corporate executives, involving estate freezing of private corporations, the settlement of family, discretionary trusts and the establishment of private charitable foundations.

Expertise

• Tax and Estate Planning

Representative Work

• Advised a Canadian bank on establishing referral agreements with selected independent trustees in tax-favoured jurisdictions for compliant, non-resident trusts for Canadians;
• Advised a Caribbean country on its tax treaty negotiations;
• Provided legal advice on transfer pricing policies of Canadian-based telecommunications corporation with significant pension plan deficit in foreign affiliate;
• Advised a multinational mining corporation on its $1.6 billion acquisition of assets from a multinational gold producer, and on its $2.1 billion acquisition of shares of another public mining corporation;
• Advised a public company on its conversion into a public income fund and with respect to ongoing issues;
• Established captive insurance companies in Barbados for a Canadian-based multinational in the steel manufacturing business and a Canadian-based real estate development company with U.S. operations;
• Developed a tax and corporate structure in Canada and the U.S.A. for a software development initiative between leading American software company and Canadian private equity fund;
• Established 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;
• 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 tax structure in connection with performances in Canada.