Background

Stephen Fyfe is a partner in the Toronto office of Borden Ladner Gervais LLP and the Manager of the Toronto Regional Tax Practice. Stephen 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 the energy markets.

Rankings and Recognitions

• Recognized in the 2011 edition of Chambers Global – The World's Leading Lawyers for Business (Tax)
• Martindale-Hubbell BV Peer Review Rating
• Selected by peers for inclusion in The Best Lawyers in Canada 2012 (Structured Finance Law)
• Recognized in the 2011 Canadian Legal Lexpert Directory (Income Funds; Investment Funds & Asset Management - Tax Aspects)

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 the structuring and finance of renewable energy projects including wind and solar. 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.
• Advised on sale of $200MM telecom business by MEU.
• Advised on corporate finance aspects of multiple solar power projects.
• Advised on $400MM merger of Northland Power Inc. and Northland Power Income Fund.
• In the investment funds area, Stephen 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

• The New Electricity Market: Financing Options, 1998 Annual Conference of the Canadian Tax Foundation, October 25-28, 1998.
• 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.
• Canadian Tax Liability for Energy Trading, Stephen J. Fyfe, May 2006, Borden Ladner Gervais firm publication in Energy Markets Bulletin for Energy Trades.
• Canada Facilitates Conversions of Income Trusts into Corporations, Corporate Finance, Federated Press, vol. XV, No. 1; International Law office August 15, 2008. Stephen Fyfe, Lindsay Holmes and Doug Powrie.
• Tax Update on the Financing of Municipal Corporations, Stephen J. Fyfe, September 2008, Borden Ladner Gervais firm publication in Tax Law Bulletin.
• Going Green in Canada - Tax Efficient Investment, Stephen J. Fyfe, June 2010 Borden Ladner Gervais firm publication in Tax Law Bulletin. It was also published in the North American Free Trade & Investment Report, vol. 20, No.11, June 15, 2010.