Grant J Russell

Grant is a partner of KPMG Tax Law LLP. His practice is focused on providing tax advice to the financial services sector including investment funds with cross-border investments, credit unions, banks, and finance companies. He also advises on offshore/international tax planning matters and frequently represents clients in negotiations and dispute resolutions with revenue agencies. 

Grant is an experienced speaker and author on both FATCA and Canada’s Common Reporting Standard.

Professional and Industry experience:

Grant has over 15 years of experience advising clients on purchase and sale transactions, mergers and acquisitions, and on shareholder and partnership issues. His current practice includes advising on cross-border investment and lending structures, and investment structuring for pension plans.

He has been the lead tax advisor on several representative transactions including:

• Industry-wide segregation of ‘mandatory liquidity pools’ held for BC and Ontario credit unions
• The mergers of notable financial and investment service providers 
• The mergers of several prominent credit unions

Publications

As a frequent speaker at tax conferences and an author of many taxation publications, his work includes:

• Current Issues," 2018 British Columbia Tax Conference (Toronto: Canadian Tax Foundation 2018), 2:1-20
• “Fresh Start Rules on Becoming an Affiliate”, XX (2) International Tax Planning (Federated Press) 1392-95 (2015)
• "FATCA for Non-Financial Institutions and the Implications of the Canada-US IGA for Canadian Institutions,” Report of the Proceedings of the Sixty-Sixth Tax Conference, 2014 (Toronto: Canadian Tax Foundation 2015), 34:1-23
• “Foreign Accrual Tax and Flow-through Entities”, XVIII (4) International Tax Planning (Federated Press)
• “The Supreme Court of Canada Releases its Decision in GlaxoSmithKline Inc. v. Canada” 2012 Volume XVIII, No. 1 International Tax
• Planning (Federated Press);
• Department of Finance Draft Legislative Proposals a Response to Lehigh” 2011 Volume XVI, No. 3 International Tax Planning
• (Federated Press);
• “Mothership Revisited – Canada’s Foreign Affiliate Regime and Active Business Income” 2010 Volume XV, No. 4 International Tax
• Planning (Federated Press);
• “CRA Requests for Information Under the Income Tax Act – A Review of Sections 231.1 and 231.2” 2008 British Columbia Tax
• Conference (Vancouver: Canadian Tax Foundation, 2008) 1:1-18
• “FIE Proposals Overview” (2007) vol. 15, no. 1 Canadian Tax Highlights
• “Hong Kong-Chinese Mainland Treaty” (2006) 14:9 Canadian Tax Highlights
• “Canada Refines Rules on Non-Resident Trusts”, International Tax Review, 2003, vol. 14, no. 6
• "Net Closes in Around Non-Resident Trusts (Parts I - II)" Offshore Investment (2002) nos. 129, 130