She was involved in the first transfer pricing appeal heard by the Supreme Court of Canada
Seasoned tax expert Amanda Heale has joined Torys’ tax team in Toronto as a partner.
She makes the jump from Osler, Hoskin & Harcourt LLP. She has tackled complex transfer pricing, international tax, and tax controversy matters.
Heale has acted for taxpayers seeking advance pricing arrangements and other competent authority relief under the country’s tax treaties. She has provided tax and risk assessment advice on matters involving mergers and acquisitions, reorganizations, and operational issues.
She assisted Cameco in the first case to consider the interpretation and application of the transfer pricing “recharacterization” rules in paragraphs 247(2)(b) and (d); this case went before the Tax Court of Canada and the Federal Court of Appeal. She also represented GlaxoSmithKline in a matter involving the transfer price of the active ingredient in a branded pharmaceutical product – this was the first transfer pricing appeal heard by the Supreme Court of Canada.
Heale worked on matters involving the Canada Revenue Agency; she helped Wheaton Precious Metals to successfully resolve a major transfer pricing dispute with the body. Moreover, she guided multinational groups in resolving at the administrative stage significant, multi-year disputes concerning the transfer pricing of intangibles, financial services, and cost contribution arrangements before the agency.
In a career that has spanned 20 years, the Lexpert-ranked lawyer has helped a multinational group negotiate a complex bilateral advance pricing arrangement. She advised TD Bank as part of a consortium on the $2.4 billion acquisition of the Aeroplan loyalty program (now Aeroplan Inc.) from Aimia Inc.
Heale advised Hydro One on its $1.83 billion initial public offering of common shares on the Toronto Stock Exchange. She helped Valeant Pharmaceuticals International to acquire Bausch + Lomb Holdings Incorporated for US$8.7 billion.
She also acted for McKesson Canada as it appealed a Tax Court of Canada transfer pricing decision to the Federal Court of Appeal; a settlement was eventually reached.
Heale got her start in private practice as an associate with Blake, Cassels & Graydon LLP, where she was a partner. According to LinkedIn, she spent the majority of her career with Osler, where she was part of the partnership.
She was on the CBA taxation section’s executive and the CPA-CBA joint committee on taxation. She was part of the University of Toronto Faculty of Law, teaching international tax.
