Grace Pereira  

Senior Counsel

Executive Summary

In her taxation of investment funds practice, Grace advises both funds and their managers and sub-advisers. She has been involved in structuring new products, restructurings, acquisitions, and wind-ups of investment funds, and with registered plans.

In her taxation of executive compensation practice, Grace is involved in all aspects of the design and implementation of tax-effective executive compensation plans for public and private employers, including stock option plans, share appreciation rights, share bonus and share purchase plans, restricted share unit (RSU) plans, deferred share unit (DSU) plans, and performance based medium and long-term incentive plans.

Grace also advises taxpayers in disputes with the Canada Revenue Agency (CRA), including acting for taxpayers in respect of transfer pricing disputes with the CRA.

Representative Work

  • Advising a Canadian Schedule 1 bank in the creation and launch of a series of new exchange-traded funds (ETFs) in the Canadian market.
  • Advising on the establishment of publicly listed real estate investment trusts (REITs) in the Canadian market.   
  • Advising on the transfer pricing disputes relevant to Canadian-based global investment managers.

Publications & Presentations

  • Author, Canadian Tax Journal, Tax Topics (CCH),  Resource Sector Taxation Newsletter (Federated Press), Taxation of Executive Compensation Newsletter (Federated Press), International Tax Newsletter (CCH), and Tax Executive Institute Newsletter (Toronto Branch)
  • Contributor, The Essential GAAR Manual: Policies, Principles and Procedures (Toronto: CCH Canadian, 2006), Canadian Transfer Pricing (Toronto: CCH Canadian 2002)