Siwei is a corporate tax partner specializing in both domestic and international contexts. With a wealth of experience across various facets of corporate tax, her expertise encompasses:
- Advising on major purchase, sale, and takeover transactions.
- Ensuring optimal tax structuring in corporate reorganizations.
- Guiding clients through cross-border corporate transactions, managing and coordinating tax complexities across multiple jurisdictions.
- Structuring financing arrangements tailored to meet the unique needs and objectives of each client.
- Designing tax structures for non-residents conducting business in Canada, providing strategic solutions to facilitate smooth operations in the Canadian market.
Siwei frequently presents on tax topics and authors tax articles. She has taken on leadership roles in the tax community such as founding a chapter of Ladies of Tax in Calgary, the steering committee for the Canadian Tax Foundation Young Practitioners, and the Young IFA Network (YIN) Committee.
Experience
- Advised on transfer pricing notices of objection and mutual agreement procedure (MAP) applications involving a multi-million-dollar adjustment for a multinational client in the energy sector.
- TBC Corporation on its sale of Midas, including Midas Canada, to Mavis Tire Express Services Corp.
- White Water Management Ltd. and its majority shareholders on the sale of Whitewater and its subsidiary, Catalyst Production Systems, to Hillcore Group, a leading Canadian investment and advisory firm.
- Matson, Driscoll & Damico, a leading international forensic accounting firm, on its sale to Davies.
- Occidental Petroleum Corp. in the acquisition of Carbon Engineering for US$1.1 billion.
- Pan American Silver Corp. (PAAS), in its US$4.8 billion acquisition of Yamana Gold Inc. shares and spinout of Canadian assets to Agnico-Eagle Mines Limited by way of Plan of Arrangement.
- POSCO Canada Limited, in the restructuring of their interest in the Greenhills and Elk Valley coal mines in southeastern British Columbia in exchange for common and preferred shares of Elk Valley Resources Inc. (EVR) and a gross revenue royalty on steelmaking coal. This transaction was part of the larger restructuring of Teck Resources Limited, into two independent, publicly-listed companies: Teck Metals Corp. and EVR.
- Berkshire Hathaway Energy Company (BHE), in its indirect share purchase acquisition of the Montana Alberta Tie-Line from Enbridge Inc. for an approximate purchase price of $200M.
- Advising international private equity funds on the acquisition of Canadian businesses.
- Numerous public and private corporations on share purchase and asset purchase transactions.
- Advised on transfer pricing notices of objection and mutual agreement procedure (MAP) applications involving a multi-million-dollar adjustment for a multinational client in the energy sector.
- TBC Corporation on its sale of Midas, including Midas Canada, to Mavis Tire Express Services Corp.
- White Water Management Ltd. and its majority shareholders on the sale of Whitewater and its subsidiary, Catalyst Production Systems, to Hillcore Group, a leading Canadian investment and advisory firm.
- Matson, Driscoll & Damico, a leading international forensic accounting firm, on its sale to Davies.
- Occidental Petroleum Corp. in the acquisition of Carbon Engineering for US$1.1 billion.
- Pan American Silver Corp. (PAAS), in its US$4.8 billion acquisition of Yamana Gold Inc. shares and spinout of Canadian assets to Agnico-Eagle Mines Limited by way of Plan of Arrangement.
- POSCO Canada Limited, in the restructuring of their interest in the Greenhills and Elk Valley coal mines in southeastern British Columbia in exchange for common and preferred shares of Elk Valley Resources Inc. (EVR) and a gross revenue royalty on steelmaking coal. This transaction was part of the larger restructuring of Teck Resources Limited, into two independent, publicly-listed companies: Teck Metals Corp. and EVR.
- Berkshire Hathaway Energy Company (BHE), in its indirect share purchase acquisition of the Montana Alberta Tie-Line from Enbridge Inc. for an approximate purchase price of $200M.
- Advising international private equity funds on the acquisition of Canadian businesses.
- Numerous public and private corporations on share purchase and asset purchase transactions.
