Patrick Marley - Osler, Hoskin & Harcourt LLP

Patrick Marley

Listed in Best Lawyers since 2006

Patrick advises on tax issues associated with international tax planning, domestic and cross-border mergers and acquisitions, corporate reorganizations, corporate finance and various other tax matters. He has experience representing clients in various industries including financial services, mining, oil and gas, telecommunications, manufacturing and technology. Patrick appeared before the Canadian Senate Banking Committee in 2008 as a tax expert in respect of proposed foreign investment entity and non-resident trust tax rules. Prior to joining Osler, Patrick worked in the Canadian Department of Finance where he was extensively involved in drafting legislation and formulating tax policy related to foreign affiliates, foreign source income and foreign investments.

Additional Information

Notable Matters
  • Bank of Montreal in connection with its acquisition of F&C Asset Management plc.
  • Royal Bank of Canada in connection with its acquisition of the Canadian automobile finance and deposit business of Ally Financial Inc.
  • Ontario Teachers’ Pension Plan in connection with their joint acquisition of Q9 Networks with Bell Canada, Providence Equity Partners and Madison Dearborn Partners for approximately C$1.1 billion in cash.
  • TD Securities (USA) LLC v. The Queen, 2010 TCC 186 - Overturned the CRA’s long-standing policy of denying treaty benefits to US limited liability companies.
  • BMO Financial Group in connection with its 2011 acquisition of Marshall & Ilsley Corporation.
  • China Investment Corporation in connection with its subsidiary’s $1.26 billion investment in PennWest Energy.
Part 2
  • China Investment Corporation in connection with its subsidiary’s US$500 million investment in secured convertible debentures issued by SouthGobi Energy Resources Ltd., a TSX-listed mining company.
  • BMO Financial Group in its acquisition of the Diners Club North American Franchise from Citigroup.
  • Kinross Gold in its acquisition of Red Back Mining Inc. (largest M&A transaction in Canada in 2010).
  • Royal Bank of Canada in its US$2.2 billion acquisition of RBTT Financial Group.
  • Royal Bank of Canada in its $1.35 billion acquisition of Phillips, Hager & North Investment Management Ltd.
  • Toronto-Dominion Bank in its US$8.5 billion acquisition of Commerce Bancorp Inc.
  • China National Petroleum Corporation (CNPC) in its US$4.2 billion acquisition of PetroKazakhstan Inc. (then the largest foreign acquisition by a Chinese company), and the subsequent sale of 33% interest in PetroKazakhstan to JSC KazMuniGas.
New York UniversityLL.M 2003University of Western OntarioLL.B 1995
Ontario Bar Association, New York Bar AssociationNew York University, International Tax Program Practice CouncilAmerican Bar Association, International SectionCanadian Tax FoundationInternational Fiscal Association

Office Location

100 King Street West
1 First Canadian Place
Suite 6200, P.O. Box 50
Toronto, ON M5X 1B8


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Practice Areas

Tax Law

Other Information

Gender: Male