Taxation of Corporate Reorganization

Presentations, lecture notes and visual aids delivered at the Federated Press Taxation of Corporate Reorganization Course held in Toronto on June 12 & 13, 2001.

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Supplementary Course Material (overhead presentation)

Structured Financing

Course Leader

John G. Lorito Stikeman Elliott

John Lorito is a partner in the income tax practice of Stikeman Elliott in Toronto. He conducts a general income tax practice specializing in corporate reorganizations and mergers and acquisitions with particular emphasis on cross-border transactions. He has advised numerous clients on the tax consequences of online and e-commerce transactions. He has also advised on tax issues relating to cross-border and domestic financial products for Canadian-based investment dealers. He has acted as counsel on federal and provincial income tax appeals before the Federal Court of Appeal and the Ontario Court (General Division). John has been a seminar leader in the Business Law Section of the Ontario Bar Admission course and the In-Depth Tax Course of the Canadian Institute of Chartered Accountants (CICA). He has written and spoken extensively on various subjects, including the uses of hybrid entities, taxation of technology transfers and the taxation of trusts. He is a member of the Canadian Tax Foundation and the International Fiscal Association.

Co-Lecturers

Ronald K. Durand Stikeman Elliott	Ronald Durand is a tax partner with Stikeman Elliott in Toronto where his practice primarily involves mergers and acquisitions, corporate reorganizations and financing arrangements. Ron is a graduate of the University of Western Ontario (B.A./Business Administration and LL.B.) and Harvard (LL.M.) and a former law clerk for the Supreme Court of Canada. He is a general editor of the Canada Tax Service published by Carswell Publishers. For a number of years Ron was a part-time lecturer in taxation at the University of Windsor and an instructor for the Canadian Institute of Chartered Accountants at their Advanced Tax Issues course. He is the author of several articles and has been a speaker at numerous conferences on income tax matters.
Ray Kinoshita, CA * PricewaterhouseCoopers LLP	Ray Kinoshita is a partner in the International Tax Services group of PricewaterhouseCoopers LLP in Toronto. Throughout his career, Ray has practised in the area of Canada–U.S. cross-border tax matters. Ray also spent two years in the International tax practice of the Amsterdam office. At present, Ray focuses on U.S. international corporate tax issues.
Melanie Kurk, CPA, CA Pricewaterhouse Coopers LLP	Melanie Kurk is a senior manager in PricewaterhouseCoopers LLP's International Tax Services group. Melanie has worked in both a "big six" public accounting firm as well as in industry in Cleveland, Ohio. In 1994, she moved to Toronto and joined PricewaterhouseCoopers as a U.S. tax specialist, and she also obtained her CA designation in Ontario. Melanie's practice is heavily focused in the U.S. state income, franchise and sales tax area. She is a member of the Ohio Society of CPAs, the American Institute of Certified Public Accountants and the Ontario Institute of Chartered Accountants.
Greg Papinko, CA, CPA Pricewaterhouse Coopers LLP	Greg Papinko is a senior manager in the International Tax Services group of PricewaterhouseCoopers LLP in Toronto, specializing in U.S. corporate and international tax matters. Greg has serviced both U.S. based and non-U.S. based multinational companies during his 11 years of corporate tax consulting practice. He actively assists clients with their U.S. and non-U.S. acquisitions and divestitures, developing and implementing world-wide tax planning strategies, developing efficient methods for repatriating foreign earnings, planning the utilization of foreign tax credits, and other international tax matters. Greg has written various tax articles for Federated Press and Canadian Tax Highlights and has presented at various seminars on U.S. tax-related matters.
Angelo Nikolakakis Stikeman Elliott	Angelo Nikolakakis is a tax partner with Stikeman Elliott in Toronto. He is also a Sessional Lecturer on Tax Policy in Practice at the Faculty of Law, McGill University, and an author or co-author of numerous articles and other works (including author of Taxation of Foreign Affiliates [Carswell, loose-leaf, 2000]). He was called to the bars of Ontario, Quebec and New York State, and is a member of the Canadian Bar Association, the American Bar Association, the International Bar Association, the Canadian Tax Foundation and the International Fiscal Association. Mr. Nikolakakis earned his B.A. and LL.B./B.C.L. degrees from McGill University in 1989 and 1993 respectively.

*  Not featured on this CD.
Biographies are accurate at the time of recording