Rami Pandher

Associate

403.260.0214
rpandher@bdplaw.com
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Education:

CPA Canada, In-Depth Tax Course - Parts I, II, III

Canadian Petroleum Tax Society, Taxation of Canadian Oil and Gas Companies

University of Western Ontario, Juris Doctor, 2013

University of Calgary, Bachelor of Commerce (Finance), With Distinction, 2010

University of Calgary, Bachelor of Arts (Economics), With Distinction, 2010

Bar admission: Alberta 2015

Industries:

Start-up and early-stage companies

Practice areas:

Estate litigation, Litigation and dispute resolution, Tax litigation, Tax

Experience

Rami's focus is on:

Tax-effective private corporation structures and reorganizations
Income tax matters related to trust and estate planning
Mergers and acquisitions
Reorganizations, restructurings and financings
Cross-border and international transactions
Taxation of non-residents
Business succession planning
Employee remuneration and compensation
Partnerships and joint ventures
Resource taxation
Tax litigation and resolution of tax disputes

Professional involvement

Professional Associations

Member, Law Society of Alberta
Section Executive, Canadian Bar Association (Taxation Section)
Member, Canadian Tax Foundation
Member, Canadian Petroleum Tax Society
Member, Calgary Bar Association
Member, The Advocate Society

Presentations

Rami has also presented at various conferences, panels, seminars, and other events, including:

GAAR Update, Canadian Petroleum Tax Society, September 2023
A discussion of the recent Deans Knight Supreme Court Case, Tax Executives Institute Inc., Calgary Chapter March 2023
Selected Tax Considerations in M&A Transactions, Canadian Bar Association (Alberta), Tax Specialists, December 2022
Breaking Up is Hard but Taxes are Harder: Tax Issues on Separation and Divorce, Canadian Bar Association (Alberta), Tax Non-Specialists, June 2021
Valuations and Related Tax Matters, Canadian Bar Association (Alberta), Taxation Non-Specialists Section, March 2020
Tax Basics of Intellectual Property, Canadian Bar Association (Alberta), Technology & Intellectual Property Section, October 2019
Tax Considerations with Earnouts and Reverse Earnouts, Canadian Bar Association (Alberta), Taxation Non-Specialists, March 2019
Introduction to Corporate Reorganizations, Canadian Bar Association (Alberta), Taxation Non-Specialists, June 2018
Selected Cross-Border Issues of Interest for Canadians Investing Abroad, Canadian Bar Association (Alberta), Taxation Non-Specialists, May 2016

Published Articles

Prior to joining BD&P, Rami has authored several articles, chapters and journals, including:

Co-Author, Practitioners Beware: Equitable Remedies Are Limited (But The Door Has Not Closed), Estates Trusts & Pensions Journal (2020), 39 E.T.P.J. 165
Author, Rectification is Back - Is Recession Next?, Canadian Tax Foundation, Tax for the Owner-Manager (Volume 20, Number 1)
Author, Rectification: Where Are We Now?, Canadian Tax Foundation, Canadian Tax Focus (Volume 9, Number 2)
Author, Rio Tinto: FCA affirms Deductibility of Oversight Expenses in M&A Transactions, Federated Press - Tax Litigation Volume XXI, No. 4 2018
Co-Author, Does Fairmont Hotels Eliminate All Equitable Remedies in the Tax Context?, Canadian Tax Foundation in (2019) 66:4 Canadian Tax Journal
Co-Author, Trust Residence Post-Fundy, Canadian Tax Foundation, Canadian Tax Highlights (Volume 26, Number 2)
Co-Author, Univar: Arm’s Length Surplus Strip Not Abusive, Canadian Tax Foundation, Canadian Tax Focus (Volume 8, Number 1)
Author, Transfer-Pricing Penalty Update, Canadian Tax Foundation, Canadian Tax Focus (Volume 7, Number 2)
Author, Fairmont: SCC Raises Hurdle for Rectification, Canadian Tax Foundation, Canadian Tax Focus (Volume 7, Number 1)
Author, Reorganization Following Arm’s Length Purchase Found Abusive, Canadian Tax Foundation, Canadian Tax Focus (Volume 6, Number 4)
Author, Transfer-Pricing Penalties Now at Issue, Canadian Tax Foundation, Canadian Tax Focus (Volume 6, Number 3)

Awards

Recent honours and recognition

Recognized by Best Lawyers in Canada as Ones to Watch in Tax Law (2023, 2024, 2025)

Wolfe Goodman Award, Ontario Bar Association, 2021

Best Newsletter Article by a Young Practitioner Award, Canadian Tax Foundation, 2018

Publications

October 7, 2024

Department of Finance Announces Relief from Bare Trust Reporting for the 2024 Taxation Year

October 27, 2022

Proposed amendments to mandatory disclosure rules

News

August 29, 2024

52 BD&P lawyers recognized in the 2025 edition of Best Lawyers Canada

August 24, 2023

Forty-one BD&P lawyers recognized in the 2024 edition of Best Lawyers Canada

November 23, 2021