Angelo Nikolakakis

Angelo Nikolakakis is a partner of EY Law LLP. Angelo is a member of the Core International Tax Services practice within the Tax Law Services group, focused primarily on advising clients on domestic and international corporate transactions – including mergers, acquisitions, reorganizations, divestitures, inbound and outbound multinational direct investment, and structured financing.

Angelo is listed in Chambers Canada and in Chambers Global as one of the leading lawyers in Canada in the field of Tax Law.

Angelo has been selected by his peers to appear in The Canadian Legal Expert Directory, validation that he is a leading lawyer in his practice area, according to the Lexpert's annual peer survey.

Experience

Angelo contributes as a sessional lecturer at the Faculty of Law, McGill University, having lectured on Taxation, Tax Policy and International Taxation.

Credentials

• Qualified to practice in Quebec (1994), Ontario (1998) and New York State (1997)
• LL.B./B.C.L., McGill University, 1993
• B.A., McGill University, 1989

Professional Accomplishments

• Spoken and written on numerous occasions on various topics of corporate and international tax law – and is the author of Taxation of Foreign Affiliates, an extensive review of the federal income tax rules applicable to outbound direct investment by Canadian multinationals, published by Carswell.
• Recognized in the Canadian Legal Lexpert Directory as a repeatedly recommended lawyer in the area of corporate tax, and has been recognized in Lexpert’s “Top 40 Under 40” surveys of leading Canadian young lawyers.
• Also recognized in other directories, including Chambers & Partners Global Directory of The World's Leading Lawyers, International Tax Review’s World Tax guides to leading tax firms and advisors, and most recently as Best Lawyers’ 2012 Montreal Tax Law Lawyer of the Year.

Cases/Publications

Select Publications

• "The Definitions of Dividends and Interest in the OECD Model: Something Lost in Translation?" [2009] no. 4 British Tax Review 406-52
• "The Unthinkable Anathema of Double Non-Taxation: The Relevance and Implications of Foreign Tax Considerations in the Context of Applying GAAR," (2010), vol. 58, Special Supplement Canadian Tax Journal, 243-301
• "The New Rules on Limitation on Benefits and Fiscally Transparent Entities," Report of Proceedings of Sixty-First Tax Conference, 2009 Tax Conference (Toronto: Canadian Tax Foundation, 2010), 26:1-59
• "Policy Forum: Who, What, Where, When, Why, and How - Discerning an Avoidance Transaction," (2009), vol. 57, no. 2 Canadian Tax Journal, 294-306
• "The Taxation of Foreign Affiliates in the Resource Sectors," Report of Proceedings of Sixtieth Tax Conference, 2008 Tax Conference (Toronto: Canadian Tax Foundation, 2009), 29:1-60
• "The Tax Treatment of Transformation Transactions," Report of Proceedings of Fifty-Eighth Tax Conference, 2006 Tax Conference (Toronto: Canadian Tax Foundation, 2007), 14:1-52
• "The Acquisition of Canadian Corporations by Non-Residents: Canadian Income Tax Considerations Affecting Acquisition Strategies and Structure, Financing Issues, and Repatriation of Profits," Report of Proceedings of Fifty-Seventh Tax Conference, 2005 Tax Conference (Toronto: Canadian Tax Foundation, 2006), 21:1-45