Natasha Miklaucic

Natasha Miklaucic  


Executive Summary

Natasha Miklaucic is a partner in the Toronto office of Borden Ladner Gervais LLP. Natasha Miklaucic practices exclusively in the tax area. Her practice includes structuring private company reorganizations; cross-border and domestic partnership, corporation and trust mergers and acquisitions; and international tax planning. Her work includes tax advice and structuring for non-Canadian corporations establishing or carrying on business in Canada and advice on cross border taxation with respect to employees or contractors working in Canada, including tax waivers. It also includes, advice for corporate clients on structuring, employee benefit taxation, executive compensation, employee/contractor remuneration issues, CPP/EI, family business tax and succession planning, domestic, deemed Canadian, cross-border and international trust advice, insurance planning, wealth management, preservation and protection strategies, personal and estate tax planning. She also provides advice on tax issues related to hospitals and professional corporations and she works in the area of tax assessment disputes, tax litigation and voluntary disclosures (tax amnesty or tax pardons) and has appeared at the Tax Court of Canada and Federal Court of Appeal.

Representative Work

  • Advising corporate clients on income tax issues arising on acquisitions, mergers, reorganizations, financings, wind-ups and amalgamations for domestic and international corporations, partnerships and trusts.
  • Structuring and implementing tax-effective plans for corporations, partnerships, trusts and individuals both domestically and internationally.
  • Providing advice to both resident and non-resident, private equity and other commercial funds, individuals and corporations on the application of the non-resident trust (NRT) and offshore investment fund rules.
  • Advising corporations with respect to Canadian, cross-border and international employee issues including taxation on termination.
  • Structuring Canadian projects for non-residents in a tax-efficient manner.
  • Providing tax advice to non-residents (both individuals and corporations) establishing or investing in business activities and properties in Canada.
  • Providing offshore insurance and trust planning for individuals and corporations.
  • Advising high net worth individual clients with respect to inter-generational wealth and estate planning.
  • Representing clients in tax disputes with the Canada Revenue Agency and the Ministry of Revenue (Ontario), including filing Objections and Appeals on behalf of clients and appearing at the Tax Court of Canada, Ontario Superior Court of Justice and the Federal Court of Appeal on income tax, GST, PST, land transfer tax, capital tax, CPP and EI matters
  • Representing corporate and individual clients with respect to voluntary disclosures.
  • Counsel to the taxpayer in the following cases:
    • Par Golf Camps Inc. v. HMQ 2001-3812(GST)
    • Simone v. R., 2005 D.T.C. 537 (TCC)
    • 1280659 Ontario Inc. V. M.N.R., 2004 TCC 138
    • Santoro v. R., 2004 D.T.C. 3684 (TCC
    • Tindall v. R., 2000 D.T.C. 2126 (TCC)
    • Thornbrook Complete Home Care Inc. v. R. 2002 2132 (TCC)
    • Thornbrook Complete Home Care Inc. v. R. 2005 FCA 22

Publications & Presentations

Natasha is a frequent blogger on the “BLG Not-for-Profit and Charity Law in Canada Blog”. This Blog is intended to be of value to anyone in Canada who has any involvement with Not-For-Profit Organizations or Charities.

  • Co-Author, "Withholding tax in the era of BEPS, CIVS and the digital economy," The International Fiscal Association Candian Branch Report (pages 129-151), June 2018.
  • Author, "Assisting Clients with Tax-Compliance: CRA's Voluntary Disclosure Program," Ontario Bar Association, October 2016.
  • Author, "The 'Panama Papers': What do they mean for you?," BLG Publication, May 2016.
  • Co-Author, "Federal Budget 2016 — Impacts on Corporation and Partnership Tax Planning Structures," BLG Labour and Employment Bulletin, March 2016.
  • Presenter, "Reg 102/105 and Cross-Boarder Compliance Issues," 65th Annual Tax Conference, November 2015.
  • Author, "Canadian Tax Consideration of Nonresidents Providing Services in Canada," Tax Notes International, March 9, 2015
  • Author, "New Canada-U.S. Initiative to Track Time Spent in Either Country Will Spotlight Cross-Border Tax Obligations," BLG Tax Law Bulletin, June 19, 2014.  
  • Presenter, "Employee or Independent Contractor? Why It's Important to Know," OBA Institute 2013, Taxation Law, Highlights of the General Practitioner, Toronto, Ontario, February 2013.
  • Author, "Doctors: Pay Lower Taxes and Keep More of your Earnings Now," Hospital News, November 29, 2012.
  • Author, "Determining Corporate Control: Canadian Court Clarifies Role of Unanimous Shareholders' Agreement," Lexology, June 11, 2012; International Law Office, June 29, 2012; Tax Notes International, July 30, 2012, p. 467; Ontario Bar Association Taxation Section Newsletter.
  • Author, "Tax Court Finds Unanimous Shareholders' Agreement Affected Legal Control of a Corporation by its Non-Resident Shareholders," BLG's Tax Law Bulletin, June 2012.
  • Author, "Employer-Provided Parking: When is it a Taxable Benefit to the Employee?", The Canadian Business Journal, May 2012; BLG Education Law Newsletter, Fall 2012; Lexology, October 9, 2012.
  • Author, "A Review of the Revised Proposed Amendments to Section 56.4," Corporate Structures and Groups, Volume XII, No. 4 2011, p. 696-702.
  • Presenter, "Employment Tax Considerations for HR Professionals," 13th Annual Labour & Employment Law Symposium, November 2010.
  • Author,"Tax Considerations for Employment Related Settlements – When Will Payments be Considered Non-Taxable?", BLG's Labour and Employment Law News, Fall 2010.
  • Presenter, "Tax Considerations for Employment Related Settlements," Law Society of Upper Canada's 6 Minute Employment Law Lawyer Session, June 2010.
  • Author, "Budgeting for a Surplus May be Dangerous," BLG's Not-For-Profit Law Update, Spring 2010.
  • Co-Author, "Budget 2010 Stock Option Changes May Necessitate Action by Issuers," BLG's Tax Law Bulletin, May 2010.
  • Co-Author, "Chapter 2 – The Non-Resident Trust and Foreign Investment Entity Rules," The Capital Guide to Canada's Hedge Fund Potential, 2nd Edition, ISI Publications, 2008.
  • Author, "Non-Resident Investments in Canada: Compliance Improvements?" CCH International Tax Journal, Report #46, June 2009.
  • Author, "FIE Rules," STEP Journal, April 2009.
  • Author, "Canadian Tax on Non-Resident Trusts," STEP Journal, January 2009.
  • Author, "The Application of the FIE Rules to Non-Resident Commercial Investment Funds," OBA Taxation Law Section Newsletter, November 2008.
  • Author, "Canada's NRT Rules May Catch Foreign Commercial Trusts with Canadian Investors," OBA Taxation Law Section Newsletter, July 2008.
  • Author, "Meaning of 'Full Voting Rights' Under Part IV," OBA Taxation Law Section Newsletter, February 2007.