Randy Morphy

Randy Morphy  

Partner

Executive Summary

Randy Morphy is a partner in the Tax Group of our Vancouver office. Randy practices in the area of corporate taxation, with a focus on resource taxation, international taxation, private equity transactions, and public company transactions such as acquisitions, reorganizations and financings. Randy has extensive experience developing and implementing international investment and holding structures for Canadian corporations with operations in foreign jurisdictions. Randy also regularly provides structuring advice to foreign entities making investments into Canada, particularly in the resource, real estate and technology sectors.

Representative Work

  • Tax counsel to Lumina Gold Corp. (formerly Odin Mining and Exploration Ltd.) in the acquisition of Ecuador Gold and Copper Corp. for $60 million, November 2016.
  • Tax counsel to Pan American Silver Corp. in the creation and sale of a portfolio of royalties, metal steam agreements and payment agreements to Maverix Metals Inc., July 2016.
  • Tax counsel to Anfield Gold in the acquisition of Magellan Minerals Ltd., May 2016.
  • Tax counsel to Panoro Minerals Ltd. in its US$140 million Precious Metals Streaming Agreement with Silver Wheaton, March 2016.
  • Tax counsel to the Vancouver Airport Authority in the sale of its 50% interest in Vantage Airport Group to Gateway Airports B.V. for $60 million, November 2015.
  • Tax counsel to Almaden Minerals Ltd. in its distribution of royalty assets by Plan of Arrangement, August 2015.
  • Tax counsel to Holloway Lodging Corporation in the acquisition of Royal Host for $157 million, July 2014.
  • Tax counsel to Lumina Copper Corp. in its sale to First Quantum Minerals Ltd. for C$470 million, June 2014.
  • ​Tax counsel to China Oil and Gas Group Limited in the acquisition of Baccalieu Energy Inc. for C$289 million, June 2014.
  • Tax counsel to Anfield Nickel in the sale of its Guatemalan subsidiary, Mayaniquel S.A., to Cunico Resources N.V. for US$105 million, June 2014.
  • Tax counsel to Reliable Parts Ltd. in its acquisition by Dot Foods and Svoboda Capital Partners for C$115 million, May 2014.
  • Tax counsel to Tolko Industries Ltd. in its sale of its Ashcroft wood treatment division to Koppers Inc. for C$31.5 million, January 2014.
  • Canadian tax counsel to the purchasers of NOK 1.81 billion senior secured floating rate notes and €225 million senior secured notes issued in respect of the acquisition of the EWOS group of companies by Altor Equity Partners and Bain Capital for NOK 6.5 billion, November 2013.
  • Tax counsel to Bonnett’s Energy Corp. in its acquisition by Mill City Capital, L.P. for C$115 million, November 2013.
  • Tax counsel to Entrée Gold Inc. in a financing arrangement with Sandstorm Gold Ltd. which included a synthetic metal stream agreement and a grant of a net smelter return royalty for US$55 million, February 2013.
  • Tax counsel to Eldorado Gold Corporation in its acquisition of European Goldfields Limited for C$2.5 billion, February 2012.
  • Tax counsel to Lumina Royalty Corp. in its acquisition by Franco Nevada Corporation for C$66 million, December 2011.
  • Tax counsel to Africa Oil Corp. in its acquisition of Lion Energy Corp. for C$25 million, June 2011.
  • Tax counsel to Lumina Copper Corp. in its distribution of royalty assets by Plan of Arrangement, June 2011.
  • Tax counsel to Africa Oil Corp. in its acquisition of Centric Energy Corp. for C$60 million, February 2011.
  • Tax counsel to Africa Oil Corp. in its acquisition of Turkana Energy Inc. for C$11 million, July 2009.
  • Tax counsel to Teck Cominco Limited in its acquisition of assets of Fording Canadian Coal Trust for US$13.9 billion, October 2008.

Publications & Presentations

  • Co-Author, "The Taxation of Grants," Canadian Current Tax, June 2016.
  • Author, “An Update on the Taxation of Farm-Outs,” vol. IX, no. 3, Resource Sector Taxation, Federated Press, 2013.
  • Author/Presenter, “British Columbia Mining Tax Overview”, Canadian Mining Taxation Strategies Conference, Toronto, September 2013.
  • Author, “The Modern Approach to Statutory Interpretation, Applied to the Section 15 Anomaly in Foreign Affiliate Financing,” (2013), vol. 61, no. 2 Canadian Tax Journal, 367-385.
  • Author/Presenter, “Flow-Through Shares and Mining Sector Financing”, Canadian Mining Taxation Strategies Conference, Vancouver, March 2013.
  • Author/Presenter, “Beneficial Ownership Provisions in Tax Treaties,” International Bar Association Annual Conference, Dublin, October 2012.
  • Author, “The Taxation of Royalties Excluded from the Resource Property Regime,” vol. IX, no. 1, Resource Sector Taxation, Federated Press, 2012.
  • Author/Presenter, “Anti-Abuse Provisions in Tax Treaties,” International Bar Association Annual Conference, Dubai, October 2011.
  • Author/Presenter, “Avoidance of Double Taxation: A Canadian Perspective,” International Bar Association Conference entitled “Double Tax Treaties: Current Developments in Latin America,” Sao Paulo, April 2011.
  • Author, “Pacific Abrasives Decision Overturned,” Resource Sector Taxation, vol. VIII, no. 2, Federated Press, 2010.
  • Author, “Means and Includes – Interpreting Internal Contradictions in Defined Terms,” Resource Sector Taxation, vol. VII, no. 2, Federated Press, 2009.
  • Author, “Canada Eliminates Withholding Tax on Arm’s-Length Debt,” International Law Office, 2008.

Rankings & Recognitions

  • Recognized as a “Corporate Lawyer to Watch” in the 2013 edition of the Lexpert® Guide to the Leading US/Canada Cross-Border Corporate Lawyers in Canada.
  • Recognized in the 2016 edition of The Canadian Legal Lexpert® Directory (Corporate Tax).