Torys: Amanda Heale Joins as Tax Partner, Boosts Canada Transfer Pricing

• Amanda Heale, a leading tax expert, has joined Torys' tax team in Toronto as a partner, moving from Osler, Hoskin & Harcourt LLP.
• She brings extensive experience in complex transfer pricing, international tax, and tax controversy matters, cultivated over a 20-year career.
• Heale was involved in the first transfer pricing appeal heard by the Supreme Court of Canada (GlaxoSmithKline) and assisted Cameco in a landmark recharacterization rules case.
• Her expertise includes successfully resolving major transfer pricing disputes with the Canada Revenue Agency for clients like Wheaton Precious Metals and guiding multinational groups through administrative resolutions.
• Beyond controversy, she has advised on significant corporate transactions, including a $2.4 billion acquisition and a $1.83 billion IPO, and is currently involved in legal education and professional organizations.

The addition of Amanda Heale to Torys' tax team represents a significant enhancement of the firm's capabilities, particularly in the highly specialized and increasingly scrutinized areas of transfer pricing and international tax.

Amanda Heale, a highly respected tax expert, has officially joined Torys' tax team in Toronto as a partner. This significant move sees Heale transition from Osler, Hoskin & Harcourt LLP, where she spent the majority of her distinguished career, including time as a partner. Her arrival bolsters Torys' capabilities, particularly in the intricate fields of transfer pricing, international tax, and tax controversy matters.

Throughout her two-decade career, Ms. Heale has cultivated a reputation for adeptly navigating complex tax landscapes. Her expertise extends to advising taxpayers on securing advance pricing arrangements and other forms of competent authority relief, which are crucial under Canada's various tax treaties. She also provides strategic tax and risk assessment guidance for major corporate activities, including mergers and acquisitions, reorganizations, and ongoing operational issues.

Ms. Heale's professional history includes involvement in several pivotal Canadian tax cases, notably the first transfer pricing appeal ever heard by the Supreme Court of Canada. In this landmark proceeding, she represented GlaxoSmithKline in a dispute concerning the transfer price of a key active ingredient in a branded pharmaceutical product. Her contributions also include assisting Cameco in the initial case to interpret and apply the transfer pricing "recharacterization" rules outlined in paragraphs 247(2)(b) and (d) of the Income Tax Act, a matter that progressed through both the Tax Court of Canada and the Federal Court of Appeal.

As a seasoned Canadian tax controversy lawyer, Amanda Heale has a strong track record of successful engagements with the Canada Revenue Agency (CRA). She played a crucial role in helping Wheaton Precious Metals resolve a substantial transfer pricing dispute with the agency. Furthermore, she has guided numerous multinational groups through the administrative stages of significant, multi-year disputes with the CRA, addressing complex issues related to the transfer pricing of intangibles, financial services, and cost contribution arrangements. Her experience also includes acting for McKesson Canada in its appeal of a Tax Court of Canada transfer pricing decision to the Federal Court of Appeal, which ultimately resulted in a settlement.

Beyond her deep specialization in tax controversy and transfer pricing, Ms. Heale has provided extensive advisory services on large-scale corporate transactions. She advised TD Bank, as part of a consortium, on the $2.4 billion acquisition of the Aeroplan loyalty program from Aimia Inc. Her expertise was also sought by Hydro One for its $1.83 billion initial public offering of common shares on the Toronto Stock Exchange. Additionally, she assisted Valeant Pharmaceuticals International in its US$8.7 billion acquisition of Bausch + Lomb Holdings Incorporated.

Recognized as a Lexpert-ranked lawyer, Ms. Heale's commitment to the legal profession extends to her involvement in key industry bodies. She is a member of the Executive of the CBA Taxation Section and the CPA-CBA Joint Committee on Taxation. Her dedication to legal education is also evident through her past role teaching international tax at the University of Toronto Faculty of Law. Earlier in her career, she began private practice as an associate and later became a partner at Blake, Cassels & Graydon LLP.

The addition of Amanda Heale to Torys' tax team represents a significant enhancement of the firm's capabilities, particularly in the highly specialized and increasingly scrutinized areas of transfer pricing and international tax. Her unparalleled experience, including her involvement in Supreme Court Canada transfer pricing cases and her proven ability to resolve complex disputes with the Canada Revenue Agency, positions her as a formidable asset. For businesses and legal professionals navigating the complexities of Canadian tax law, her move to Torys signals a strengthened resource for expert counsel in these critical domains.

Her comprehensive background, encompassing both high-stakes litigation and strategic transactional advice, ensures that Torys can offer an even more robust suite of services to clients facing intricate tax challenges. This strategic hire underscores the growing importance of specialized expertise in Canada's evolving tax landscape, particularly for multinational corporations dealing with cross-border transactions and regulatory scrutiny.

The addition of a highly experienced tax partner like Amanda Heale, known for her work on landmark transfer pricing cases, significantly strengthens Torys' tax controversy and international tax capabilities. Lawyers and compliance officers facing complex transfer pricing disputes or seeking advice on international tax structures in Canada should be aware of this move, as it impacts the competitive landscape for expert legal counsel in these specialized areas.

Source: Reporting based on industry news