Blake specializes in taxation with a focus on international taxation and transfer pricing, dispute resolution (including litigation), and tax aspects of corporate finance, reorganizations and merger and acquisitions. From 1989 to 1990, Blake was Senior Counsel to the Standing Committee of the House of Commons on Finance and Economic Affairs with respect to the implementation of the goods and services tax. He has presented papers for, among others, the American Bar Association, the Canadian Bar Association, the Canadian Institute of Chartered Accountants, the Canadian Tax Foundation, the Law Society of Upper Canada and the Tax Executives Institute.
- General Motors in its successful out of court restructuring.
- General Electric Capital Canada Inc. adviser in a transfer pricing dispute regarding deductibility of guarantee fees.
- GlaxoSmithKline adviser in a transfer pricing dispute regarding the alleged overpayment for the supply of medication into Canada and an associated licence.
- Advice with respect to the shut-down and relocation of Canadian operations.
- Advice on restructuring Canadian operations to maintain treaty benefits under the Canada US Tax Convention.
- Various MAP requests regarding, among other things, automotive parts, consumer goods, luxury products and trademark royalties.
- Various APAs regarding, among other things, automotive parts, consumer goods, luxury products and trademark royalties.
- Various transfer pricing disputes regarding, among other things, valuation of interest payable under intercompany loans, valuation of intercompany management services, valuation of foreign subsidiaries, existence of technology and royalty valuation, alleged disposition of customer lists in the course of business restructuring, valuation of buy-in payment for cost sharing arrangement., deemed dividends and transfer pricing penalties.