Nathan Boidman

Background

Boidman, Nathan was born on August 22, 1940 in Montreal, Quebec.

Education

McGill University (Bachelor of Commerce, 1962. Bachelor of Civil Law, 1980. Bachelor of Laws, 1980).

Spoken languages: French and English.

Career

Worked at Goodman Phillips & Vineberg (Montreal, QU) specializing in Corporate, Estates and Trusts, Finance, Immigration, Mergers and Acquisitions, Real Property, Taxation. Admitted to the bar, 1981, Québec. Authorships: Books: 1987: "United States.

Tax Reform—The Canadian Perspective," (co-authorship) Commerce Clearing House Canadian Limited, October 1987.

1985: "The New United States. Residency Rules for Canadians—Tax Considerations," (co-authorship) Commerce Clearing House Canadian Limited.

"Taxation in Canada—Implications Foreign Foreign Investment," (co-authorship) Kluwer, Law and Taxation Publishers. 1983: "The Foreign Affiliate System: Canadian Taxation After 1982—A Structured Overview," published by Commerce Clearing House Canadian Limited.

Services: 1995 Chapter 15, "Foreign Tax Considerations Foreign United States.

Investments," (co-authorship), Warren Gorham & Lamont, 1995. 1989: Chapter on Canada "Tax Treatment of Transfer Pricing," International Bureau of Fiscal Documentation, 1989 (Updated 1994). 1986: Chapter on Canada "Canadian Law and Practice," Spitz: Tax Havens Encyclopedia Service, Issue 21, 1986 (Updated 1994).

1984: Chapter B8-Canada in "International Tax Systems and Planning Techniques," Longman Law, Tax and Finance (Updated 1996).

Tax Management Portfolio: 1995: Chapter 31: "Transfer Pricing Rules and Practice in Canada," Tax Management Incorporated., 1995. Other Contributions to Books: 1993: Chapter in Essays on International Taxation, "Interrelated Effects of Canadian and United States Tax Systems Over the Past Twenty-Five Years," published by Kluwer, 1993.

1991: Chapter on Canada, "International Joint Ventures—The Legal and Tax Issues," Eurostudy Publishing Company Limited., England, 1991 (Updated March 1993). 1988: Chapter on Canada "Tax Treatment of International Cost-Contribution Arrangements," Kluwer, International Bar Association.

Articles (Partial Listing): 1996: Nathan Boidman, "Revised Protocol Impacts on Canadian/United States.

Concerns," International Tax Report, January 1996, p.5. Nathan Boidman, "Canada: The Applicability of Transfer Pricing Rules to ‘Transactions’ Between a Head Office and Its Foreign Permanent Establishment(s)," International Transfer Pricing Journal, Volume 3, 1996, Number. 1, p.37; Nathan Boidman, "The 1995 Canada-United States.

Treaty Protocol: Some Reflections and Commentary," Tax Notes International, Volume 1, Number.

23, March 31, 1996, p.731. Nathan Boidman, "An Analysis of the Canada-United States.

Income Tax Treaty Protocol," Tax Management International Journal, Volume 25, Number. 3, March 1996, p.160.

Nathan Boidman, "Canada Cuts Down Radical Proposals to Tax Foreign Investors," Tax Management International Journal, Volume 25, Number.

8, August 1996, p.517. Nathan Boidman, "Canada Follows Lead of the United States. in Ravaging Departing Persons," Tax Management International Journal, Volume(s) 25, December 1996. 1995: Nathan Boidman, "Canada Agrees Bilateral APAs and Finalizes New Procedures," International Tax Report, March 1995, p.1.

Nathan Boidman, "Canada to extend Taxing Jurisdiction to Foreigners," International Tax Report, April 1995.

Nathan Boidman, "Can an Efficient Transfer Pricing Strategy Be Developed Under Canadian Law," The Tax Executive, Volume 47, Number. 4, July-August 1995, p.290.

Nathan Boidman, "Canadian Perspective on the Final Section 482 Regulations," Tax Management International Journal, Volume 23, Number. 11, November 1994, p.553.

Nathan Boidman, "Transport World Oil & Gas Limited. v.

The Queen—Another Loss Importer Loses," Tax Management International Journal, Volume 23, Number. 12, December 1994, p.618. Nathan Boidman and Claude East. Jodoin, "Master of Computer Applications Television Limited—Films and Treaties," Tax Management International Journal, Volume 24, Number.

1, January 1995, p.47.

Nathan Boidman, "Revenue Canada Revises Software Royalty Stance," Tax Management International Journal, Volume 24, Number. 1, January 1995, p.49.

Nathan Boidman, Foreign Affiliate Amendments—Late Update," Tax Management International Journal, Volume 24, Number. 3, March 1995, p.156.

Nathan Boidman, "Final Foreign Affiliate Amendments: Bill C-70," Tax Management International Journal, Volume 24, Number.

4, April 1995, p.191. Nathan Boidman, "Canadian Budget Brief," Tax Management International Journal, Volume 24, Number. 4, April 1995, p.204.

Nathan Boidman, "Revised Canada-United States.

Treaty Protocol: An Overview," Tax Management International Journal, Volume 24, Number. 5, May 12, 1995, p.236.

Nathan Boidman, "Canadian Taxation of Foreign Investments: Radical Extension of Jurisdiction," Tax Management International Journal, Volume 24, Number. 6, June 9, 1995, p.286 (seperate article, not part of column).

Nathan Boidman, "Competent Authority Proceedings: Information Circular 71-17R4," Tax Management International Journal, Volume 24, Number.

7, July 1995, p.331. Nathan Boidman, "Supreme Court of Canada: Corporate Residency for Treaty Purposes—Brief Overview," Tax Management International Journal, Volume 24, Number. 8, August 1995, p.386.

Nathan Boidman, "Canada"s Radical Proposals to Tax Foreign Investment Structures," Tax Planning International Review, Volume 22, Number.

7, July 1995, p.10. Lecture-Papers (Partial Listing): 1996: Organizer of an Lecturer at the Joint Meeting/Seminar of the Canadian Branch and United States of America Branch of International Fiscal Association, Montreal, June 6-7, 1996, paper delivered "The Canadian & United States Tax Systems: Evolving Similarities and Remaining Differences," Lecture on "Tax Reform in China, An International Symposium," Department of Economics, Huron College, University of Western Ontario, London, Ontario, August 9-11, 1996. 1995: "Panel on Cross-Border Investment & Operations Among Canada, Mexico & the United States.," The Florida Bar, 13th Annual International Tax Conference, Miami, January 19-20, 1995.

"Canadian Acquisition/Disposition Planning," World Trade Institute, Seminar: Tax Aspects of Doing Business in Canada, New York, July 13-14, 1995, New New York

"How To Develop An Efficient Transfer Pricing Strategy Under Foreign Law (Canada), Executive Enterprises, Incorporated. Conference on Intercompany Transfer Pricing, Chicago, December 1-2, 1994. University and Special Courses (Partial Listing): Lectures: Bachelor Commerce Program, Concordia University, Montréal, International Business Law, Lecture on International Tax, February 5, 1996 and October 30, 1996.

Masters in Taxation Program, University of Sherbrooke, Québec, Lectures on Transfer Pricing and Foreign Investment in Canadian Real Estate, 1993 and Transfer Pricing 1994 and 1995.

Graduate Diploma in Taxation Program, McGill University, Department of Chartered Accountancy and Graduate Administrative Studies: Courses on United States. Taxation since 1992-1995.

Two-Day Executive Training Course Centre, Revenue Canada Taxation, Lecture on Transfer Pricing, Ottawa, March 25-26, 1996. Five-Day Executive Training Course Center—Career for Career Development, Revenue Canada Taxation, Lectures of Transfer Pricing, Toronto, December 1993 and Calgary, October 1994.

Appointments (Partial Listing): Nominated for the Board of Governors of the Canadian Tax Foundation, June 1996.

Panel Chairman and Discussion Leader, Subject I: Transfer Pricing In the Absence of Comparable Market Prices, 46th Congress, International Fiscal Association, Cancun, Mexico, October 11-15, 1992. President, November 1995 and Member of Council, 1983, Canadian Branch of International Fiscal Association (I.F.A.). Past Member, Joint Committee on Taxation, Canadian Bar Association and Canadian Institute of Chartered Accountants, 1983.

Achievements

• Nathan Boidman has been listed as a reputable lawyer by Martindale-Hubbell.

Works

• Other Work

  • Books: 1987: "Tax Treatment of Transfer Pricing," Chapter on Canada, International Bureau of Fiscal Documentation, 1987. "United States. Tax Reform - The Canadian Perspective," in Co-Authorship with Gary J. Gartner, published by CCH Canadian Limited, October 1987. 1986: Canadian Law and Practice," Chapter on Canada, Spitz: Tax Havens Encyclopaedia Service, Issue 21, 1986.
    
    1985: "The New United States. Residency Rules for Canadians - Tax Considerations," in CoAuthorship with L. Frank Chopin and Alan W. Granwell, published by CCH Canadian Limited, "Taxation in Canada - Implications For Foreign Investment," In Co-Authorship with Mr. Druno Ducharme, Esq., published by Kluwer, Law and Taxation Publishers.
    
    "Chapter on Canada," International Tax Systems and Planning Techniques, published by Oyez Longman. 1983: "The Foreign Affiliate System: Canadian Taxation After 1982 - A Structured Overview," published by CCH Canadian Limited. Articles: 1988 The Canadian Approach to Offshore International Transactions: An Update," The Tax Executive, Vol 40 No.
    
    3, Spring 1988, p. 383. "Inter-Company Transfer Pricing: Developments - Appeal Court Comes Down on Transshipment Companies," International Tax Report, March, 1988, p.5. "Revenue Canada’s Transfer Pricing Circular: Selected Commentary," Canadian Tax Journal, Volume 36, No.
    
    2, March-April 1900, p. 405

  • "Update on Transfer Pricing: Indalex v. The Queen,” Tax Management International Journal,- Volume 17, No.
    
    4, April 1988, p. 156. "Canada: An Offshore Transshipment Company Case: Indalex v. The Queen," International Bureau of Fiscal Documentation - Bulletin," May, 1988, p.
    
    202: "Intercompany Pricing - Irving Oil Case," Tax Management International Journal," Volume 17 No. 6, June 1988, p. 251. "Tax Planning for Foreign Investment in Canadian Real Estate," Tax Planning International Review, Vol 15, No.
    
    8, August 1988, p.12. 1987 "Canada’s Administrative Guidelines for Multinational Transactions: Information Circular No. 87-2," The Tax Executive, Volume 40 No.
    
    1, Fall 1987, p. 35

  • "Canadian Tax Reform Proposals - A Response to the United States. Tax Reform Act of 1986," Tax Management International Journal, Volume 16 No. 8, August 1987, p. 318.
    
    "Canada’s New Administrative Guidelines for Multinational Transactions: Information Circular No. 87-2 (Analysis and Comparison with IRC Section 482 Regulations and the OECD Guidelines),” Tax Management International Journal, Volume 16 No. 11, November 1987. (For additional authorships see biographical data in 1983, 1986, 1987 and 1988 Editions of Martindale-Hubbell).
    
    Lectures-Papers: 1988: "Canadian and United States. Tax Reform - Comparisons & Cross-Border Effects," for the Florida Bar/Florida Institute of Certified Public Accountants, Sixth Annual Conference on International Tax, Miami, Florida, January 14-15, 1988. "Creating The Most Effective Plan for Foreign Real Estate Investors," for Institute of International Research, Toronto, Canada, June, 1988.
    
    "The Impact of United States. & Canadian Tax Reform on Cross-Border Investments," for American Bar Association, Section on Taxation, Toronto, Ontario, August, 1988. Co-Developer and Co-.

Membership

Bar of Quebec; Canadian Bar Association. Canadian Tax Foundation. Institute of Chartered Accountants of Ontario and Order of Charterd Accountants of Quebec.

Appointments: The Canadian Branch of the Business and Advisory Committee (BIAC) to the O.E.C.D. Tax Management Advisory Board on Foreign Income, 1981.

Tax Management International Journal Advisory Board, BNA, Washington, 1982.

Joint Committee on Taxation of the Canadian Bar Association and Canadian Institute of Chartered Accountants, 1983. Council, Canadian Branch of International Fiscal Association (I.F.A.) 1983.