Gwen Watson

Gwen Watson

Counsel
Toronto: 416.865.7962
Fax 416.865.7380

Education

LLB (concentration in taxation), 1997
University of Western Ontario
B. Acc (co-op accountancy stream), 1994
Brock University

Bar Admissions

Ontario, 1999

Overview

Gwen provides income tax advice to corporate clients, with particular emphasis on mergers and acquisitions and corporate reorganizations, including butterfly and bump transactions, as well as the income tax aspects of cross-border and capital markets transactions, derivatives and financial instruments. Gwen also has significant expertise in advising clients on the application of the Canadian foreign affiliate rules.

Insights

“Draft Legislation Amending Subsection 55(2) of the Income Tax Act,” Insurance Planning, Federated Press

"The ‘Purpose’ of Subsection 55(2),” Ontario Tax Conference Report

“Beneficial Owner: The Canadian Approach in the OECD Context,” Corporate Finance, Federated Press

“Treaty Shopping and Base Erosion and Profit Shifting Action 6,” Canadian Tax Journal

“Hedging Transactions and the Linkage Principle,” Corporate Finance, Federated Press

Professional Involvement

Gwen is a member of the Joint Committee on Taxation of the CBA and CPA Canada and has been a tutorial leader for the Corporate Reorganizations course offered by CPA Canada. Gwen completed a secondment at the Income Tax Rulings Directorate of the CRA as a Senior Rulings Officer in the Corporate Reorganizations section.

Memberships and Affiliations

  • Canadian Tax Foundation
  • Canadian Bar Association
  • International Fiscal Association