Byron Scott Beswick

Byron is a CPA, CA and a lawyer whose practice is focused on inbound and outbound cross-border taxation matters and domestic and cross-border mergers, acquisitions, financings and reorganizations. Byron has 20 years of public practice experience as an accountant and a lawyer and is ranked by Lexpert and Best Lawyers in Canada as a leading Canadian corporate tax lawyer.

Byron is a frequent writer and speaker on taxation matters, including for the Canadian Tax Foundation, Canadian Tax Journal and International Fiscal Association, and is a professional development instructor for the Chartered Professional Accountants of Canada.

Professional and Industry Experience:

Byron has extensive domestic and cross-border tax planning and transaction experience with some of the largest Canadian-based multi-national enterprises in Western Canada, as well as major foreign public, private and state-owned enterprises investing in Canada. Byron’s clients have included entities primarily in the energy, energy services, commodities, manufacturing, engineering and real estate industries.

Recent Teaching Experience

• CPA Canada, Lecturer, In-Depth In-Residence III, 2023, 2022, 2021
• University of Calgary Faculty of Law, Sessional Instructor, International Tax, 2020, 2019, 2018

Recent Presentations, Publications and Conference Organization 

• Co-Chair for Canadian International Fiscal Association Conference, 2023
• “Foreign Affiliates for the Owner-Managed Business Advisor”, panelist and paper for Canadian Tax Foundation Prairie Provinces Tax Conference, 2023
• “Subsection 55(2): Recent Developments and Issues Regarding the Recharacterization of Inter-Corporate Dividends”, presentation, Canadian Petroleum Tax Society, 2023
• “Interest Deductibility and Hybrid Mismatch Arrangement Rules”, panelist for Canadian International Fiscal Association Conference, 2022
• “Transfer Pricing for Debt Transactions”, panel moderator for Canadian Tax Foundation Transfer Pricing Conference, 2022 
• “Selected Topics in Transfer Pricing”, panelist for Canadian Tax Foundation Transfer Pricing Conference, 2021
• “International Tax for Owner-Managers: An Introduction for Non-Specialists”, presentation and paper for Canadian Tax Foundation Owner-Manager Conference, 2020, with Michael Dolson
• “Canada - Overview of Canadian Fiscal and Tax Administrative Measures in Response to the COVID-19 Pandemic”, Bulletin for International Tax, 2020, with Brett Anderson
• “Selected Tax Issues in Debt Reorganization Transactions”, presentation and paper at Canadian Tax Foundation Annual Conference, 2019, with Jim Samuel
• “Transfer Pricing and Transactions Between Foreign Entities”, paper, Canadian Tax Journal, 2019 
• “Selected Aspects of US Tax Reform”, presentation, Tax Executives Institute, 2018, with Siobhan Goguen
• “Foreign Exchange Legislation in Canada: Current State and Future Policy”, presentation and paper at Canadian Tax Foundation Annual Conference, 2017, with Tony Ancimer
• Moderator for CRA Roundtable, Canadian International Fiscal Association Conference, 2017
• “Foreign Exchange Management and Recent Developments”, presentation, Tax Executives Institute, 2016
• “OECD Final BEPS Reports – The Readers Digest Version”, panelist for Joint CTF/IFA Tax Planning Conference, 2016, with Ron Durand, Jim Samuel, and Claire Kennedy
• “Primer on Inbound Taxation Matters”, presentation to Young International Fiscal Association Network, 2016 
• “Tax Risks and Opportunities in a Challenging Economy”, presentation, Canadian Petroleum Tax Society, 2015
• “Developments in the Canadian LNG Industry”, presentation, Canadian Petroleum Tax Society, 2014
• “The Evolving Fiscal Regime for BC LNG Projects”, presentation and paper, 2014, with Andrew Azmudeh
• “Canadian Consolidation Strategies”, presentation, Canadian Bar Association, Tax Specialists Section, 2014 
• “Canadian LNG Industry Update”, paper, Federated Press, 2014
• “Tax Considerations for LNG Players”, presentation, Canadian Petroleum Tax Society, 2013
• “Foreign Exchange Issues and Strategies”, presentation, Canadian Petroleum Tax Society, 2012
• “Inbound Transactions”, presentation to Canadian Tax Foundation Young Practitioners, 2012
• “The Use of Holding Companies in the Private Business Context”, paper, Canadian Tax Journal, 2012, with Beau Young
• “Foreign Exchange Issues and Strategies”, presentation, Canadian Bar Association, 2012
• “Alternatives for Deal Structuring and Operating Structures”, presentation, Acumen, 2012
• “Partnership Deferral Rules”, article, CA Magazine, 2011
• “Canadian Taxation of Foreign Exchange Gains and Losses”, paper, Tax Notes International, 2009, with Steve Suarez
• “Transfer Pricing Disputes in Canada” in “Resolving Transfer Pricing Disputes: A Global Analysis”, chapter of book, Cambridge Tax Law Series, 2008, with David Duff