Ryan is a tax partner and Co-Chair of the firm's Tax Group.  His legal practice focuses on various areas of domestic and international taxation, including advising on mergers and acquisitions, structured investment products, financings, estate plans, employment tax issues and a broad range of corporate tax matters. Ryan also represents clients with voluntary disclosures, audits and appeals, and he has been lead counsel at every level of court, including the Supreme Court of Canada.

Ryan regularly presents on income tax topics at conferences and other venues, and has been quoted in national publications on income tax matters. Ryan is the Tax Editor of Ontario Corporate Law & Practice and is also the co-editor and a frequent contributor to the Current Cases feature of the Canadian Tax Journal, the flagship research publication of the Canadian Tax Foundation.

In 2016, Ryan was recognized as one of Canada's Lexpert® Rising Stars: Leading Lawyers Under 40. More recently, he was named a Corporate Lawyer to Watch in the 2017 Lexpert Guide to the Leading US/Canada Cross-Border Corporate Lawyers in Canada.


Ryan Morris is Co-Chair of the firm's Tax Group.  His practice focuses on domestic and international tax planning, estate planning, and tax dispute resolution. In 2016, Ryan was recognized as one of Canada's Lexpert® Rising Stars: Leading Lawyers Under 40 and he was recently named a Corporate Lawyer to Watch in the 2017 Lexpert Guide to the Leading US/Canada Cross¬Border Corporate Lawyers in Canada.

Ryan is a tax partner and Co-Chair of the firm's Tax Group.  His legal practice focuses on various areas of domestic and international taxation, including advising on mergers and acquisitions, structured investment products, financings, estate plans, employment tax issues and a broad range of corporate tax matters. Ryan also represents clients with voluntary disclosures, audits and appeals, and he has been lead counsel at every level of court, including the Supreme Court of Canada.

Ryan regularly presents on income tax topics at conferences and other venues, and has been quoted in national publications on income tax matters. Ryan is the Tax Editor of Ontario Corporate Law & Practice and is also the co-editor and a frequent contributor to the Current Cases feature of the Canadian Tax Journal, the flagship research publication of the Canadian Tax Foundation.

In 2016, Ryan was recognized as one of Canada's Lexpert® Rising Stars: Leading Lawyers Under 40. More recently, he was named a Corporate Lawyer to Watch in the 2017 Lexpert Guide to the Leading US/Canada Cross-Border Corporate Lawyers in Canada.


Notable Mandates

Significant Cases

Represented individuals against director liability assessments for failed source deduction and HST remittances.

Represented corporations and individuals where the Canada Revenue Agency has claimed working relationship mischaracterized.

Represented multi-national publicly listed corporation on transfer pricing dispute.

Represented individuals assessed for various items in connection with participation in a leveraged donation and investment program.

Represented individuals in connection with "section 160" assessments (vicarious liability where property received from non-arm's length party for less than fair market value).

Represented taxpayers in connection with denied deductions, alleged shareholder benefits and alleged unreported income. 

Represented individual who profited from innocent participation in a Ponzi scheme, which later became the feature case in the 2014 Donald G.H. Bowman National Tax Moot.

Significant Transactions

Acted for Norrep Capital Management Ltd in completing the initial public offering of the Norrep Short Duration 2017 Flow-Through Limited Partnership.

Acted for Soltoro Ltd. (TSX Venture: SOL) in connection with its successful disposition by plan of arrangement to Agnico Eagle Mines Limited pursuant to which Agnico Eagle acquired 100% of the issued and outstanding common shares of Soltoro for total consideration of approximately C$32 million.

Representation of Big 5 Bank with respect to, among other things, (i) equity-linked notes and related offerings, including providing structuring advice, drafting withholding tax opinions and tax disclosure for information statements, and (ii) drafting and advising with respect to tax disclosure in Annual Information Forms for closed-end funds.

Acted for another Big 5 Bank as senior lender agent on all tax aspects of reorganization proceeding of large Canadian media company.

Advised on numerous public offerings of some of Canada's largest corporations, including the offering of subscription receipts, preferred shares, flow-through shares and ordinary common shares as well as various debt offerings.

Advised on numerous public and private investment fund offerings.

Represented numerous resource companies in respect of flow-through share and warrant offerings.

Advised a leading diversified energy company with respect to multiple sales of coal properties in Alberta.

Advised with respect to numerous solar project acquisitions.

Advised with respect to numerous Canadian acquisitions and dispositions by US private equity firms.

Represented numerous lenders and borrowers with respect to entering into or renegotiating credit facilities.

Publications

"Government Backtracks on Anti-Surplus Stripping Proposals, and Looks to Develop Alternative Proposals", WeirFoulds LLP, October 2017

"Proposed Tax Measures to Limit Deferral Benefits of Acquiring Passive Investments in Private Corporations", WeirFoulds LLP, October 2017

"Government Backtracks on Certain Income Tax Proposals Impacting Private Corporations and their Shareholders", WeirFoulds LLP, October 2017

"Beware: Proposed Tax Changes May Require you to Act Now", WeirFoulds LLP, September 2017 (with Maralynne Monteith and Lori Duffy)

"Sweeping Tax Proposals to Impact Private Corporations, Their Shareholders (including Family Trusts) and Post-Mortem Tax Planning", WeirFoulds LLP , July 2017

Partnership Taxation: Overview", Practical Law, March 2017

Hello CCA Class 14.1, Goodbye Eligible Capital Property", Practical Law, January 2017

"Non-Resident Employer Certification Regime: Withholding Relief for Non-Resident Employers and Employees", WeirFoulds LLP, June 2016

"Panama Papers and Offshore Accounts: Window of Opportunity to Make a Voluntary Disclosure Closing", WeirFoulds LLP, May 2016

"US Employees Coming to Work In Canada: Recent Tax and Immigration Law Developments", 2016 Lexpert/American Lawyer Guide to the Leading 500 Lawyers in Canada, January 2016 (with Jacqueline Bart)

"Energy/Tax Law Update 2015", WeirFoulds LLP, April 2015 (with Robert Warren)

"International Tax Law Update 2015", WeirFoulds LLP, April 2015

"Employment/Tax Law Update 2015", WeirFoulds LLP, April 2015

"Quiz: Voluntary Disclosure Program", InHouse Magazine, December 2014

"Client Newsletter - Fall 2014", WeirFoulds LLP Client Newsletter, September 2014 (with Ralph Kroman, Wayne Egan, and Bradley McLellan)

"Relief for Victim of a Ponzi Scheme", Canadian Tax Journal, Vol. 62, No. 3, pp. 819–25, November 2014

The Essential Guide to Settlement in Canada, LexisNexis Canada, December 2013 (with Ben Bathgate, Brent McPherson, George Waggott, et al.)

"If a Tree Falls in the Forest...Daishowa-Marubeni International Ltd. v. Canada", Canadian Tax Journal, Vol. 61, No. 3, pp. 723–29, October 2013

"An Interesting Interpretation, Bozzer v. The Queen et al.", Canadian Tax Journal, Vol. 58, No. 2, pp. 340-46, July 2010

"Chapter 49 – Canada West", International Contract Manual, a Thomson Reuters Business, March 2010 (with Frank Archibald,  Sharon Groom, Jamie Wilks, et al.)

"Surveying the Scene After Prévost Car Hits the Federal Court of Appeal", Canadian Tax Journal, Vol. 57, No. 2, pp. 307-315, July 2009

"Gone Fishing: Canada (National Revenue) v. Greater Montréal Real Estate Board", Canadian Tax Journal, Vol. 56, No. 2, pp. 469-501, December 2008

"Procedure! Procedure! Procedure!", Canadian Tax Journal, Vol. 54, No. 4, pp. 928, February 2007

"On the Hook: Directors Liability for Corporate Tax Transgressions", OBA Taxation Law Article, May 2005 (with Les Chaiet)

"Contingent Liabilities: The Special Canadian Contingency Fund", Canadian Tax Journal, Vol. 52, No. 1, pp.158, May 2004

"Efficiency Defence and Canadian Welfare" – Recipient of the Canadian Bar Association's 2003 James H. Boking Memorial Award for the best scholarly paper relating to Canadian competition law or policy, June 2003

Speaking Engagements

Speaker, "Legal and Regulatory Issues Facing Building Owners and Property Managers", SpringFest, Toronto, ON, April 5, 2018

Speaker, "Business Succession Planning update", TD Wealth Management, Toronto, ON, November 30, 2017

Speaker, "Scary Tax Issues for Wills and Estates Practitioners", Junior Trust and Estates Planning group (JTEP), Toronto, ON, October 20, 2017

Speaker, "Current Cases", 2017 Ontario Tax Conference – Canadian Tax Foundation: Toronto, ON, October 23, 2017

Speaker, "The Tax Man a Cometh: Fight or Flight?", itaxpartners Seminar, Toronto, ON, June 1, 2017

Speaker, "Taxation of Damages & Settlements on Termination of Employment", WeirFoulds Employment & Labour Law Group Client Seminar, Toronto, ON, April 6, 2017

Speaker, "Structuring Real Estate Projects", itaxpartners Seminar, Toronto, ON, December 14, 2016 and January 11, 2017

Speaker, "Subsection 55(2) and Safe Income", itaxpartners Tax Traps and Preventive Planning Seminar, Vaughan, ON, November 24, 2016

Speaker, "Small Business Deduction & Eligible Capital Property Regimes", itaxpartners Seminar, Vaughan, ON, November 14, 2016

Speaker, "Planning and Litigation: Financial Products and Their Implications to Your Practice", Ontario Bar Association, Toronto, ON, October 20, 2016

Speaker, "The Tax Man A Cometh: Fight or Flight?", WeirFoulds LLP, Toronto, ON, September 20, 2016

Speaker, "Startup Legal and IP", Founder Institute, Toronto, March 14, 2016

Course Leader, "9th Tax Planning for the International Client", Federated Press, November 12 & 13, 2015

Course Leader, "12th Taxation of Financial Products & Derivatives Course", Federated Press, September 28 & 29, 2015

Lecturer, "Tax Considerations for M&A Deals", Federated Press: 3rd M&A Agreements Course, September 24 & 25, 2015

Lecturer, "Employing Foreign Workers: Tax Issues", Federated Press: 3rd Employing Foreign Workers Course, May 20 & 21, 2015

Course Leader, "4th Tax-Effective Succession Planning for the Owner-Manager", Federated Press, May 12 & 13, 2015

Lecturer, "Post-Mortem Tax Planning for Private Company Shares", Federated Press: 4th Tax-Effective Succession Planning for the Owner-Manager, May 12 & 13, 2015

Co-Chair, "3rd Tax Planning for the Sale of a Business Course", Federated Press, January 29 & 30, 2015

Speaker, "Business Dispositions by Non-Residents", Federated Press: 3rd Tax Planning for the Sale of a Business, January 29 & 30, 2015

Speaker, "Tax Advantages and Disadvantages of a Corporation", WeirFoulds Women Entrepreneurs Roundup 2.0, November 6, 2014

Speaker, "The Dos and Don'ts of Independent Contractor Relationships: Employment and Tax Perspectives", WeirFoulds Joint Tax Law and Employment, Human Rights and Labour Law Seminar, October 29, 2014

Speaker, "Canadian Tax Implications of Owning Foreign Property", Presentation to the Hellenic Canadian Lawyers' Association and the Hellenic Canadian Board of Trade, October 22, 2014

Speaker, "Potential Tax Problems and Opportunities in Will Challenges", Ontario Bar Association: Essential Tax Issues Every Estate Litigator Should Know, October 9, 2014

Speaker,"Tax Considerations for M&A Deals", Federated Press: 2nd M&A Agreements Course, September 16 & 17, 2014

Co-Chair, "11th Taxation of Financial Products & Derivatives Course", Federated Press, September 9 & 10, 2014

Co-Chair, "10th Taxation of Financial Products & Derivatives Course", Federated Press, September 26 & 27, 2013

Speaker, "Latest on Income Taxes & Incentives for Resource Companies and Investors", Federated Press: 3rd Understanding Natural Resources Taxation, June 11, 2013

Speaker, "Five Common Income Tax Concepts Applicable to a Commercial Lease", The Six-Minute Commercial Leasing Lawyer 2012,The Law Society of Upper Canada, February 2012

Speaker, "Update on Section 116 Tax Clearance Certificate Regime Presentation", Canadian Young Practitioners Group, Canadian Tax Foundation, November 2010

Awards & Recognition

Recognized in the 2017 Lexpert Guide to the Leading US/Canada Cross-Border Corporate Lawyers

2016 Lexpert® Rising Stars: Leading Lawyers Under 40

Professional Activities

Tax Editor, Ontario Corporate Law & Practice

Co-editor, Current Cases feature of the Canadian Tax Journal

Past steering committee member, Toronto Young Practitioners Group

Affiliations

Canadian Tax Foundation

Ontario Bar Association

Canadian Bar Association

Partner

Toronto
Direct 416.947.5001
Fax 416.365.1876
rmorris@weirfoulds.com

Practice Areas

Tax Law

Tax Dispute Resolution

Called to the Bar
Ontario, 2003
Education
University of Toronto
J.D. 2002

Richard Ivey School of Business, University of Western Ontario
H.B.A. 1999

CPA Canada
In-Depth Tax Course,
Part I and II

CPA Canada
In-Depth
HST/GST Course

Awards & Recognition

Recognized in the 2017 Lexpert Guide to the Leading US/Canada Cross-Border Corporate Lawyers

2016 Lexpert® Rising Stars: Leading Lawyers Under 40

Professional Activities

Tax Editor, Ontario Corporate Law & Practice

Co-editor, Current Cases feature of the Canadian Tax Journal

Past steering committee member, Toronto Young Practitioners Group

Affiliations

Canadian Tax Foundation

Ontario Bar Association

Canadian Bar Association

Called to the Bar

Ontario, 2003

Education

University of Toronto
J.D. 2002

Richard Ivey School of Business, University of Western Ontario
H.B.A. 1999

CPA Canada
In-Depth Tax Course,
Part I and II

CPA Canada
In-Depth
HST/GST Course