Mr Stephen J Fyfe Partner Borden Ladner Gervais LLP - Lawyer Biography - International Law Office

International Law Office

Lawyer Biography

Mr Stephen J Fyfe

Background

Stephen Fyfe is a tax partner in our Toronto office. Mr. Fyfe was admitted to the Ontario Bar in 1986 and the Alberta Bar in 1984. He graduated from Queen's University Law School in 1982.

Areas of Practice

  • Stephen has extensive experience with respect to the business, structuring and tax implications of mergers, acquisitions, corporate reorganizations, financings and other business transactions. He is committed to understanding a client's business and providing them with effective and practical tax advice by taking a problem solving approach to resolving their concerns. In recent years, Stephen has become increasingly involved with clients working in energy markets.

Professional Experience

  • In the energy markets area, Stephen has been involved with the structuring of income trusts, both as an exit strategy for independent power producers and as a financing vehicle. Stephen has also worked on the acquisition and financing of a number of large electricity generation projects, with a particular focus on renewable energy. He provided tax and structuring advice to numerous municipal utilities, assisting them in their transition to the competitive energy markets area and continues to assist them with corporate tax planning today.
  • In the investment funds area, Stephen has has become increasingly involved with tax advantaged structured products, making use of various derivative based structuring alternatives available. He was also involved with the first securitization structures for the investment fund area, and the development of the first income trusts used to finance redemption charge securities.

Professional and Community Activities

  • Member of the International Fiscal Association, Canadian Tax Foundation.

Publications

  • Emerging Issues in Financing the Sale of Redemption Charge Securities, The Canadian Institute in March 1995 Conference on Current Developments in the Mutual Fund Industry.
  • Non-Resident Acquisitions of Canadian Businesses, CBAO Institute of Continuing Legal Education, annual conference January 1996.
  • Financing Mutual Fund Sales Commissions - Recent Innovations, Federated Press Financial Products Summit, Toronto, March 31, 1998.
  • Winning the Game: Tax Effective Financing, Synergy Energy Conference, Toronto, October 19, 1998.
  • The New Electricity Market: Financing Options, Canadian Tax Foundation, 1998 Annual Tax Conference, October 25-28, 1998.
  • Clone Funds: Structuring Your Fund to Ensure Regulatory Compliance, Institute for International Research, February 1, 2000.
  • Current Mutual Fund Developments and Products, Canadian Tax Foundation, September 24-27, 2000.
  • Opportunities for Municipally Owned Corporations in Ontario's Electricity Market, Stephen J. Fyfe and William McLean, in 2002 Canadian Tax Journal, Volume 50, N o 3, page 970.
  • Tax Advantaged Closed-End Investment Trust, Stephen J. Fyfe and Jonathan Willson, in 2003 Federated Press Corporate Finance vol. X, number 4, page 988.
  • U.S. Investment Funds Tax Strategies for Canadian Real Estate Securities, Stephen J. Fyfe, presented at American Bar Association Joint Fall CLE Meeting, Chicago, September 11-13, 2003.
  • The Taxation of Renewable Energy Investments in Canada, Stephen J. Fyfe, presented at Insight's "How to Profit from the Business of Renewable Energy" Conference, October 20-21, 2003.
  • Application of Foreign Investment Entity Rules to Outbound Investments by Canadian Mutual Funds, Stephen J. Fyfe, in December, 2003 CCH International Tax Publication
    " REOP Proposals Create Significant Tax Planning Issues, Stephen J. Fyfe, Spring, 2004, Borden Ladner Gervais firm publication in Tax Law Update.
  • Structured Products - Choosing A Structure for Split Capital Funds, Stephen J. Fyfe, Fall, 2004, Borden Ladner Gervais firm publication in Tax Law/Investment Funds Bulletin.
  • Closed End Funds and Covered Call Options, Stephen J. Fyfe, January, 2005, Borden Ladner Gervais firm publication in Tax Law/Investment Funds Bulletin.
  • Tax Issues Affecting Distributors in the Electricity Markets, Stephen J. Fyfe and Francesco Gucciardo, January 27, 2005, presented at the Electricity Distribution Systems & Technology Conference.
  • Canada Extends Source Taxation for Investment Funds, Stephen J. Fyfe, February, 2005, Borden Ladner Gervais firm publication in Tax Law/Investment Funds Bulletin.
  • Canadian Tax Liability for Energy Trading, Stephen J. Fyfe, May 2006, Borden Ladner Gervais firm publication in Energy Markets Bulletin for Energy Trades.
  • Transfer Tax Update, Stephen J. Fyfe, William McLean and Francesco Gucciardo, October 2006, Borden Ladner Gervais firm publication in Energy Markets Bulletin.
  • Structured Products and the Proposed SIFT Legislation, Stephen J. Fyfe and Craig Webster, January 10, 2007, Borden Ladner Gervais firm publication in Tax Law/Investment Funds Bulletin.
  • SIFT Relief for Closed-End Investment Funds, Stephen J. Fyfe, January 23, 2008, Borden Ladner Gervais firm publication in Tax Law/Investment Funds Bulletin.
  • Flaherty Foregoes New Shoes to Deliver Budget Message, Stephen J. Fyfe, Gar Knutsen, Sal Mirandola, Elinore Richardson and Daniel Lang, February 26, 2008, Borden Ladner Gervais firm publication in Tax Law/Investment Funds Bulletin.

Speaking Engagements

  • Stephen spoke at the Federated Press Tax-Effective Private Equity & Investment Funds Seminar on May 16, 2006. His presentation was called "Innovative Investment Strategies for Closed End Funds".
  • Stephen spoke at the Federated Press Taxation of Corporate Reorganizations Conference on January 10, 2007 on the "Reorganization of Structured Products".
  • Stephen spoke at the Canadian Institute's Symposium on Retail Structured Projects on April 24, 2007 on "Managing Tax Risks for Structured Products".
  • Stephen spoke at the Ontario Bar Association 2008 Institute of Continued Legal Education on January 5, 2008 on "Strategic Issues for Income Trusts " with Philippe Tardif".