Todd Miller Photo
Todd Miller Photo
Todd Miller Photo

Todd Miller practises tax law with an emphasis on domestic and cross-border financing transactions (public and private), transfer pricing and international tax treaty matters, securities offerings, and mergers and acquisitions. He also provides counsel on reorganizations and business divestitures, and representation before the Tax Court of Canada.

With a broad scope of expertise, Todd provides advice on matters relating to private equity investments, joint venture / partnership agreements, estate planning and employee compensation. Assisting clients in a range of sectors including banking and manufacturing, he also provides advice on the taxation of charities and other non-profit organizations.

Todd is a regular author and speaker on a variety of tax matters such as cross-border business acquisition strategies, outbound planning for Canadian multinationals and partnership planning opportunities. He is a member of the Canadian Tax Foundation and the Canadian branch of the International Fiscal Association and a national leader of TRC-Sadovod’s Tax Group.




News


Media Mentions


Rankings & Recognition

  • Todd Miller is recognized in the 2024 ITR World Tax Guide as a Notable Practitioner
  • Listed in the Legal500 Canada 2020 as a “Recommended Lawyer” – Tax

Directorships & Affiliations

  • Canadian Bar Association
  • Canadian Tax Foundation
  • International Fiscal Association (Canadian Branch)

Education & Admissions

1995
Called to the Ontario bar
1993
LLB Osgoode Hall Law School
1993
BA, Economics York University

Publications

  • Practice Note, Transfer Pricing: Overview,” Practical Law Canada – Corporate and M&A (September 2021)
  • “Canadian Branch Profits Tax – Challenging the Denial of Treaty-Benefits for US LLCs,” TerraLex Connections Newsletter (January 2014)
  • “Canada: Audit Guide,” World Transfer Pricing 2014 – International Tax Review (October 2013)
  • “Canadian Q&A chapter for the 11th edition of the Practical Law Company Employee Share Plans Multi-Jurisdictional Guide” (October 2012)
  • “The New RRSP/RRIF Anti-Avoidance Regime: a Roadmap and Tips for the Unwary,” Taxation of Executive Compensation and Retirement Journal (April 2012)

Insights (6 Posts)View More

Featured Insight

Budget 2023: Employee Ownership Trust Measures Unveiled

Consistent with the Federal Government’s (the “Government”) prior statements in Budget 2022, Budget 2023 proposes amendments to the Income Tax Act (Canada)

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Mar 31, 2023
Featured Insight

Budget 2021: Expansion of Mandatory Disclosure Rules

Budget 2021 proposes to significantly expand the mandatory disclosure rules contained in the Income Tax Act.

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Apr 23, 2021
Featured Insight

Budget 2018: Tempered Private Company Passive Investment Income Changes Unveiled

Budget 2018 introduced measures to limit the tax deferral advantages perceived to be afforded to private company investment income.

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Mar 9, 2018
Featured Insight

Budget 2016: Significant International Tax Proposals Unveiled

Budget 2016: Significant International Tax Proposals Unveiled

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Mar 31, 2016
Featured Insight

Budget 2015: Tax-Free Savings Accounts – A Welcome Contribution Limit Increase, but “Prohibited Investment” Rules Remain a Concern

Budget 2015 proposes to increase the TFSA annual contribution limit from January 1, 2015. The TFSA annual contribution limit will no longer be indexed to inflation.

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Apr 29, 2015

Deals & Cases (9 Posts)

Featured Insight

PURE Reciprocal Insurance Exchange obtains Order from OSFI to Insure in Canada Risks

On February 9, 2023, Privilege Underwriters Reciprocal Exchange obtained an approval from the Superintendent of Financial Institutions under the Insurance Companies Act to insure in Canada personal lines property and casualty risks, including those falling under the classes of property, liability, marine and automobile insurance

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Feb 9, 2023
Featured Insight

Thoma Bravo acquires Autodata Solutions Group

Thoma Bravo acquires Autodata Solutions Group

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May 30, 2019
Featured Insight

Thoma Bravo acquires Aucerna

Thoma Bravo acquires Aucerna

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May 14, 2019
Featured Insight

Dynamic Paint Products enters into a US$70M Credit Agreement

TRC-Sadovod LLP represented Dynamic in Canada with a Toronto-based team comprising Todd Miller, Brett Stewart, Michelle Boodhoo and Anthony Pallota.

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Apr 2, 2019
Featured Insight

Thoma Bravo acquires technology-focused parking management systems provider T2 Systems

Thoma Bravo acquires technology-focused parking management systems provider T2 Systems

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Sep 29, 2016
Featured Insight

Thoma Bravo acquires autoTRADER Corporation for C$1.575 billion

Thoma Bravo acquires autoTRADER Corporation for C$1.575 billion

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Sep 28, 2016

Wind Mobile secures senior debt facility with Canadian banks syndicate to build out LTE network

Wind Mobile secures senior debt facility with Canadian banks syndicate to build out LTE network

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Dec 10, 2015
Featured Insight

Davide Campari-Milano S.p.A. acquires Forty Creek Distillery Ltd.

Davide Campari-Milano S.p.A. (Campari) acquired Forty Creek Distillery Ltd.

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Jun 2, 2014
Featured Insight

Hammond Kennedy Whitney & Co. acquires a majority stake in Royal Camp Services Ltd

Hammond Kennedy Whitney & Co. acquires a majority stake in Royal Camp Services Ltd

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Nov 23, 2011