Ben Hardwicke-Brown

Associate, Tax Law, KPMG Law LLP

KPMG in Canada

Ben’s practice focuses on domestic and international corporate tax planning. Prior to starting at KPMG, Ben worked for four years as a senior within the International Tax and Transactions Services Group at another leading professional services firm. 

Ben specializes in providing Canadian outbound tax advice to multi-national companies and has experience in the preparation and review of both surplus and foreign accrual property income computations. 

During his time at KPMG, Ben has advised on both corporate and partnership debt restructurings, Canadian income tax consequences in relation to overseas acquisitions, specifically, in the context of the foreign affiliate regime, and information reporting requirements by non-residents after the disposition of taxable Canadian property. 

 

Professional and Industry Experience

Canadian Restructurings

Ben has assisted on multiple restructurings within the oil & gas, mining, technology and entertainment industries:

  • Assisted in planning and execution of multi-billion-dollar retail asset migration project with no resulting federal, provincial, or indirect tax; 
  • Drafted step-plan and opinion providing tax implications of billion-dollar U.S. re-financing to facilitate asset acquisition, involving entities in Luxembourg, Hungary and Uruguay resulting in less than 4% leakage; and
  • Assisted in corporate structural planning to facilitate global delivery of traveling exhibit

Surplus Computation

Ben served as a project manager for the development and implementation of an Azure based universal surplus computation application to automate the ordering and allocation of surplus pools between foreign affiliates of a Canadian taxpayer. This allowed for the seamless computation and reporting of surplus for multiple Canadian taxpayers holding over 100 foreign affiliates. As part of the development of this application, Ben primary responsibilities included managing a team of overseas developers, testing and configuring the system functions, and the conceptualization and implementation of features to increase the overall usability of the application.  

  • JD/MBA (SPEC: FNCE), University of Calgary and the Haskayne School of Business

  • Bachelor of Commerce (Marketing). University of Alberta

  • Member of the Law Society of Alberta

  • CICA In-Depth Taxation Course (expected completion 2022)

  • Law Society of Alberta

  • Calgary Bar Association

  • Canadian Petroleum Tax Society

  • Canada Bar Association