Andrew Morreale

Andrew Morreale

Baker & McKenzie LLP


Andrew Morreale is a partner in Baker McKenzie's Tax Practice Group in Toronto. Prior to joining the Firm, Andrew clerked for the judges of the Tax Court of Canada, was a corporate tax instructor at the University of Windsor, Faculty of Law and practiced in the international tax services group at a major accounting firm.

Practice Focus

Andrew's practice focuses on domestic and cross-border mergers and acquisitions, corporate reorganizations, financing and capital market transactions. Andrew has particular experience advising on outbound structuring and tax treaty issues. He also has expertise in advising underwriters, issuers and investors in respect of flow-through share offerings and investments.

Andrew also assists with tax dispute matters, most recently in the context of entitlement to treaty benefits, upstream loans, and the classification of foreign legal instruments.

Representative Legal Matters

  • Advised Affirm, Inc. on its acquisition of PayBright Inc. for total cash and equity consideration of CAD 340 million.
  • Advised the Embracer Group on multiple acquisitions in Canada.

Professional Associations and Memberships

  • Canadian Tax Foundation
  • Law Society of Ontario


  • Ontario (2013)


  • University of Windsor (JD) (2011)
  • University of Ottawa (BSocSc Political Science) (2009)


  • English


Speaker, "A Case Study in Canadian and Select European Controlled Foreign Company/Foreign Affiliate Rules" IFA YIN Webinar, October, 2021

Speaker, “Foreign Affiliate Update” CTF Annual Tax Conference, December 2019

Speaker, "Owner-Manager Outbound International Tax Traps, Planning Considerations & Practical Solutions," CTF Ontario Tax Conference, October 2017


Co-author, Future Law and Alternative Facts, XXI:1 Tax Litigation 6 (Federated Press), February 2018

Author, "Functional Currency Election Not Available to Branches," Canadian Tax Focus, February 2016

Co-author, "Specific Anti-Avoidance Rules Trump GAAR," Canadian Tax Focus, November 2016