Barry Horne

Barry Horne, seasoned in the realms of international and mergers and acquisitions (M&A) tax law, harnesses his profound tax expertise, extensive experience, and innovative technology, like project management tools, to optimize the outcomes of various transactions for his clients. Over his career, Barry has become adept at collaborating with multidisciplinary teams, an approach he has intensified since becoming a partner at a leading accounting firm and its law affiliate over the past five years. His ability to work seamlessly with both domestic and international groups has enabled him to craft comprehensive solutions and uncover critical issues that might have remained unnoticed through a purely legal lens.

In the sphere of international tax, Barry excels at guiding clients through the maze of cross-border tax challenges, aiming to enhance their global tax advantages. His strategies include devising tax-efficient structures, leveraging tax attributes, and managing the tax implications of inbound investments, among others. Barry's expertise extends to minimizing withholding taxes, interpreting tax treaties, and advising on hybrid entities and instruments to dodge or lessen the impact of anti-hybrid rules.

Furthermore, Barry works closely with transfer pricing specialists to refine the definition and distribution of functions and risks, alongside drafting precise transfer pricing agreements. He also collaborates with international advisors to reduce the overall effective tax rate for multinational groups, ensuring the maximization of Canadian income and withholding taxes for foreign tax credit purposes.

In the M&A tax landscape, Barry's practice is all-encompassing, covering due diligence, structuring transactions for tax efficiency, and advising on post-acquisition tax optimization. He is particularly adept at simplifying corporate structures post-merger and integrating operations into a unified global framework. His role often involves crafting the tax-specific language in acquisition agreements and strategizing on M&A transactions, especially those involving private equity and complex loan arrangements for financing.

Barry's 32-year tenure in tax law, including five transformative years at a Big Four accounting firm, has broadened his skill set and roles significantly. His participation in specialized groups within the firm, such as the International Tax Services and International Global Structuring groups, highlights his expertise in identifying cross-border opportunities. Additionally, as a pioneer member of the Legal Business Solutions group, Barry provides strategic advisory services, showcasing his versatility beyond traditional tax advice. His involvement in the Pathfinder and International Business Reorganizations groups demonstrates his capability to offer tailored advice to foreign businesses in Canada and coordinate multinational reorganizations with precision.

Barry's admission to the bar in Ontario, Nova Scotia, and Alberta, combined with his academic credentials from Dalhousie University in both law and commerce, solidifies his foundation as a tax law expert. His career is a testament to his leadership in navigating the complexities of international and M&A tax law, reflecting a commitment to excellence and innovation in his field.