Practice Areas
+U.S. Taxation
+Canadian Taxation
+International Estate Planning
+International Tax Controversy
+International Law
+Corporate/Commercial Law
Bar Admissions
+Province of Ontario, 1992
+State Bar of New York, 1993
+U.S. District Court, S.D.N.Y., 1994
+U.S. Tax Court, 1994
+U.S. Court of International Trade, 1994
+Solicitor, Supreme Court of England and Wales, * 2000
+Licensed Foreign Legal Consultant, Ontario, 2005
Offices
+Toronto (416) 594-1596
+New York City (212) 859-3506
Education
+LL.M. (ILS), NYU School of Law, 1993
+LL.M. (Tax), NYU School of Law, 1994
+J.D., Queen’s University Faculty of Law, 1990
+HBA, UWO, Ivey School of Business, 1987
David S. Kerzner specializes in designing and implementing international tax strategies for private business clients and families in North America. David’s corporate tax practice includes: all aspects of international tax planning for multinational enterprises, international financings, investments in real property, and transfer pricing. David’s practice for individuals includes international relocation planning, international estate planning, and international tax controversy before the IRS. David also acts in the capacity of U.S. General Counsel and U.S. Tax Director for Canadian clients with investments in the United States.
David is the Editor-In-Chief and Principal Co-Author of The Tax Advisor’s Guide to the Canada-U.S. Tax Treaty (a two volume, two thousand page treatise on the international tax laws of Canada and the U.S.) published by Thomson-Reuters-Carswell with Vitaly Timokhov. He is also the Co-Author of The Manager’s Guide to International Taxation (a book for CEO’s, CFO’s, and COO’s) with Prof. Arthur Cockfield, JSD (Stanford).
David is an Adjunct Professor in taxation at Queen’s University Faculty of Law, Kingston Ontario; a Research Fellow in the Department of Business Law & Taxation at Monash University, Melbourne Australia; and a Professor (Emeritus) in taxation at the Washington Institute for Graduate Studies in San Diego, California.
David’s past experience includes advising Fortune 50 companies on M&A and international tax matters from the National Tax Headquarters of KPMG LLP in Washington, D.C., and the firm’s flagship offices in New York City and Century City. David has proudly served in the United States Navy (Reserves) and the United States Marine Corps (4th Marine Division).
Recent Books/Articles/Lectures
The Tax Advisors’s Guide to the Canada -U.S. Tax Treaty (Thomson-Reuters-Carswell, 2008) (Loose-leaf, 2 Volumes)
Editor-in-Chief and Principal Co-Author with Vitaly Timokhov
The Manager’s Guide to International Taxation (Thomson-Reuters-Carswell, 2010)
Co-author with Prof. Arthur Cockfield, JSD (Stanford)
U.S. International Taxation of the Transfer of Technology:
A Primer for CFOs, Tax Directors, & Foreign Tax Advisors in
The Taxation and Valuation of Technology, (D. Chodikoff & J. Horvath, eds., Irwin Law, 2008).
U.S. Voluntary Disclosure and Strategic Wealth Planning
for Americans in Canada , IT’S PERSONAL,
Thomson-Reuters-Carswell, Vol. 3, Issue 6, November 2010
Themes in the Taxation of Trusts, Lecture
Queen’s University Faculty of Law, November 4, 2009.
Cross Border Dimensions in Residence, Webinar, with Vitaly Timokhov,
Thomson-Reuters-Carswell, September 17, 2009.
Of Summer’s Past and the Fall of the Tax Evaders, IT’S PERSONAL,
Thomson-Reuters-Carswell, Vol. 2 Issue 4, September 2009.
Permanent Establishments, Basics and Beyond, Webinar,
with Vitaly Timokhov, Thomson-Reuters-Carswell, July 8, 2009.
IRS Intensifies Efforts to Investigate and Prosecute Willful
Violators Who Hide Offshore Accounts and Income,
IT’S PERSONAL, Thomson-Reuters-Carswell, Vol. 2 Issue 3, May 2009.
U.S. Taxation of Canadian Businesses: The Role of Agents,
Faculty of Law, Queen’s University, March 23, 2009 (Lecture).
The Preservation of Wealth under the New U.S. Exit Tax Rules:
Avoiding the Minefields and Ticking Time Bombs Facing
U.S. Citizens and Green Card Holders Living Abroad,
IT’S PERSONAL, Vol. 2 Issue 2, March 2009.
Protocol to U.S.-Canada Treaty Introduces
New 15 Percent Withholding Tax Rate for Contingent Interest,
JOURNAL OF TAXATION OF FINANCIAL PRODUCTS,
Volume 7 Issue 4 (2008), Co-Author with Angela W.Y. Yu.
*Non-practicing status.
Franklyn E. Cappell , Barrister & Solicitor / Sr. Counsel
Practice Areas +Canadian Tax Planning
+Canadian Tax Litigation
+Canadian Trusts & Estates
+Corporate/Commercial Law
+Investments into Canada
Bar Admissions
+Province of Ontario
Office
+Toronto (416) 703-0103
Education + LL.M. Harvard Law School, 1966
+LL.B. Dalhousie Law School, with distinction, 1964
+B. Comm., Dalhousie University, 1961
Franklyn specializes in all aspects of Canadian tax law and litigation. Franklyn’s considerable experience includes advising clients on cross border investments into Canada and Canadian corporate and commercial law. Franklyn is of counsel to Kerzner Law.
Susan Robins , Barrister & Solicitor / Sr. Counsel
Practice Areas +Canadian Tax Planning
+M & A Reorganizations
+Cross Border Tax Planning
+ Transfer Pricing
+International Planning for IP
+Family and Business Succession Planning
Bar Admissions +Province of Ontario, 1981
Office
+Toronto (416) 482-0186
Education
+LL.B., University of Toronto, 1979
Susan’s thirty years of tax experience includes holding senior tax management positions in multinational corporations, in addition to being a partner in two large public accounting firms, Ernst & Young, and Arthur Andersen. She is of counsel to Kerzner Law.
Vitaly Timokhov , Barrister & Solicitor / Counsel
Practice Areas +Canadian Tax Planning
+International Tax Planning
+Cross Border Tax Planning
+Tax Treaty Law
+International Relocation
+Government Advisory
Bar Admissions +Province of Ontario
+Province of Alberta
+State Bar of New York
Office
+Toronto (647) 727-4400
Education +LL.M. (Tax) NYU School of Law
Vitaly specializes in all aspects of Canadian international tax law. He is a past lecturer at Osgoode Hall Law School and the Senior Editor and Principal Co-Author of The Tax Advisor’s Guide to the Canada-U.S. Tax Treaty (a two volume, two thousand page treatise on the international tax laws of Canada and the U.S.) published by Thomson-Reuters-Carswell with David Kerzner. Vitaly is of counsel to Kerzner Law.