Tax
Tax Planning & Advisory
For over 25 years, LPN has advised many of Canada's most prominent families, founders, and privately held enterprises on the full spectrum of personal and corporate tax planning — bringing technically precise, creative counsel to situations where the stakes are highest and the answers are rarely obvious. We are retained not only by our own long-standing clients, but regularly by other legal and accounting professionals seeking an additional layer of specialized tax expertise on demanding mandates.
Our tax planning is proactive, integrated, and deeply personal. We take the time to understand each client's full picture — their family structure, their business interests, their long-term intentions — before recommending a course of action. Every plan we design is built to be technically defensible, practically workable, and aligned with what our clients are actually trying to achieve.
The design of a corporate structure carries significant and long-lasting tax consequences. We advise on holding company arrangements, the establishment and restructuring of partnership and limited partnership structures, loss utilization strategies within complex corporate groups, and the tax dimensions of capital reorganizations, amalgamations, and continuances. Our work in this area spans private companies, family enterprises, real estate development structures, and closely held investment groups — always with attention to both the immediate tax outcome and the longer-term implications for the people behind the structure.
Where planning involves technically demanding or novel positions, we bring the depth of experience and creative rigour required to design structures that are both effective and defensible. When those positions are challenged, we are equally prepared to defend them with precision and authority.
Corporate Tax Structuring
Major transactions and succession events are among the most consequential moments in the life of a private enterprise. We advise on the tax dimensions of business sales, acquisitions, and reorganizations — including the application of the Lifetime Capital Gains Exemption, estate freezes, pipeline arrangements, post-mortem planning, distributions from family trusts, capital dividend planning and the repatriation of profits from domestic and international operations. Our objective is to ensure that our clients understand and optimize their tax position at every stage of a transaction — from initial structuring through closing and beyond.
Succession planning intersects tax, corporate, and estate law in ways that require genuine coordination across disciplines. We work closely with our clients' lawyers, accountants, financial advisors, and estate planning counsel to ensure that the tax dimensions of generational transitions are addressed with the same care and precision as the legal and structural elements — producing plans that are coherent, coordinated, and built to last.
Tax & Succession Planning
Our tax mandates reflect the depth and range of the challenges our clients bring to us. Representative engagements have included the structuring and sale of a prominent technology enterprise, with comprehensive advice on transaction tax, exemption planning, and post-closing arrangements for the principals; tax planning for major Canadian real estate developers, including the design of GP/LP structures for multiple development projects and strategies for the efficient repatriation of profits; cross border insurance planning for a large investment fund; implementation of IP structures; and the design and defense of planning structures in the context of CRA audit and dispute proceedings.
We have also advised extensively on the application of the Lifetime Capital Gains Exemption across multiple shareholders and corporate structures; loss utilization arrangements within complex, multi-entity corporate groups; and holding company and partnership structures designed to achieve tax efficiency for families and enterprises across a range of asset classes and investment activities. In each matter, our role has been to bring technically precise, creative counsel to situations where the conventional answer was insufficient.