At Fogler, Rubinoff, we believe that making a difference begins with trust. Experience and sound judgment earn it. Client relationships are built on it. Results keep it.

Ian V. MacInnis




Ian is a Partner in the firm's Tax Group. His tax practice involves advising on a broad range of tax matters, including corporate reorganizations, cross-border transactions, acquisitions and divestitures, financings, personal tax and estate planning, tax dispute resolution and voluntary disclosures.



NOVEMBER 01 2018

Multiple Wills Alert!

A recent decision of the Ontario Superior Court of Justice (Re Milne) may affect the Wills of clients who have used multiple Wills to reduce probate fees. If you have Primary and Secondary Wills in place, this court decision may put that planning in jeopardy...

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OCTOBER 12 2018

Beware of State and Local Taxes on Remote Sales into the United States

The recent decision of the Supreme Court of the United States (the "USSC") in South Dakota v. Wayfair, Inc. (No. 17-494), has substantially expanded the taxation powers of the U.S. States to collect sales tax.

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DECEMBER 19 2017

Revised Income Splitting Proposals

On July 18, 2017, the Department of Finance released a series of controversial tax proposals aimed at closing perceived tax "loopholes" that involve the taxation of private corporations and their shareholders...

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OCTOBER 12 2017

Significant Restrictions To The Voluntary Disclosures Program

The Voluntary Disclosures Program (VDP) is a "tax amnesty" program administered by the Canada Revenue Agency ("CRA")...

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JULY 19 2017

Major Proposed Changes To The Taxation Of Private Corporations And To Severely Limit Income Splitting

The Federal Government released a set of proposals on July 18, 2017 that, in the government’s words, are designed to "improve fairness in the tax system by closing loopholes and addressing tax planning strategies" and to ensure "that the richest Canadians pay their fair share of taxes and that people in similar circumstances pay similar amounts of tax" (a summary of the proposals and related documentation can be found at

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APRIL 24 2017

Dollars and Sense Spring 2017

Ontario announced a 15% tax on the purchase or acquisition of an interest in residential property located in the Greater Golden Horseshoe ("GGH") by individuals who are not citizens or permanent residents of Canada and by foreign corporations ("foreign entities") and certain taxable trustees.

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APRIL 19 2017

Reporting Now Required To Claim The Principal Residence Exemption ("PRE")

The long-standing administrative policy of the CRA was not to require an individual to report the disposition of a principal residence if there was no capital gain remaining after applying the PRE...

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OCTOBER 17 2016

Dollars and Sense Fall 2016

The principal residence exemption ("PRE") is one of the most significant "tax breaks" available under the Income Tax Act (Canada) (the "Act")...

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JULY 18 2016

Dollars and Sense Summer 2016

The 2015 Federal Budget contained significant amendments to section 55 of the Income Tax Act (Canada) (the "Act"). These amendments recently became law and will generally apply retroactively to dividends received after April 20, 2015

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OCTOBER 29 2015

FR Dollars and Sense

MARCH 19 2015

FR Dollars and Sense

MAY 13 2014

FR Dollars and Sense

Representative Work

LexPert Big Deals

ConceptWave Software Inc.

  • Acted as counsel to ConceptWave Software Inc. and certain founding shareholders on the September 2012 acquisition by Ericsson Canada Inc.

Canadian Solar Solutions Inc.

  • Advised on tax matters for Canadian Solar Solutions Inc. in connection with December 2011 master purchase and sale agreement with TransCanada Corp. for turnkey solar farms.
  • Acting for Issuers and Agents on numerous flow-through share financings.
  • Representation of domestic and foreign clients on outbound and inbound translation structuring.
  • Acting in real estate investment and divestiture structuring matters.
  • Advising on tax matters for investment funds, including Mutual Fund Trust, Mutual Fund Corporations and Limited Partnerships.
  • Advising on purchase and sale of Canadian private corporations.
  • Advising with respect to corporate reorganizations, financings, acquisitions and divestitures.
  • Advising Owner-Managers and high net worth individuals on tax and estate planning matters.
  • Advising Estate-Trustees on post-mortem tax planning, including "pipeline" reorganizations.



  • FR Dollars and Sense
  • Canadian Real Estate Income Tax Guide (Co-Author/Editor Wolters Kluwer)
    - A quarterly looseleaf and electronic publication on the income tax and GST/HST aspects of real estate
  • Tax Topics (Wolters Kluwer)
    - Various articles from 1996 to 2012
  • The Controlling Mind - The Tax Perspective (Carswell - Contributing Author)
  • Canadian Taxation of Real Estate (4th Edition), 2004 (Co-Author with Michael Atlas, C.A., CCH Canadian Limited)
  • Reasonable Expectation of Profit and Other Heresies (2002 Ontario Tax Conference)

Speaking Engagements

  • Presentations at accounting firms on income tax, GST/HST and Land Transfer Tax matters
  • Buying or Selling a Business: An Overview of Tax Considerations (Ontario Bar Association - Institute 2013)
  • GST Aspects of Certain Arm's Length and Non-Arm's Length Transfers of Real Estate and Different Business Transactions
    - Ontario Bar Association program entitled "Taxation of Real Estate Transactions - A User's Guide", September 18, 2007


  • Canadian Tax Foundation
  • Society of Trust and Estate Practitioners (STEP)
  • Guitar Society of Toronto - Past President
  • Canadian Bar Association
  • Law Society of Upper Canada


  • Admitted to Ontario Bar, 1989
  • Osgoode Hall Law School, LL.B., 1987
  • McGill University, B. Comm., 1984

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