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Canada: Recent developments in Canadian tax controversy and litigation

Risk-based assessment of large corporations

The Canada Revenue Agency (CRA) audits large corporate taxpayers on a regular basis. To improve efficiencies and cash recoveries, CRA is moving to a risk-based assessment approach to auditing such taxpayers. Over the next five years, corporate taxpayers will be assessed as low, medium and high risk, based on a series of factors. The frequency and intensity of the audit processes will vary directly with the risk ascribed to the particular taxpayer. Consequently, large corporations which now face consistent audit scrutiny on domestic and cross-border tax issues may find that CRA audit work abates or becomes more focused on specific areas in which significant tax liabilities may arise. Two areas of continuing review involve transfer pricing and aggressive tax planning. CRA regards the latter term as one referring to arrangements which comply with the letter but not the spirit of the statutory provisions that give rise to tax benefits.

Increased demands for information by tax authorities

The CRA is using its powers under the Canadian Income Tax Act (ITA) to compel the delivery of both domestic and foreign-based information. Instructions to complete questionnaires, requests for tax planning memoranda and demands for e-mail exchanges are three of the strategies used to gather information. Failure to comply may result in the issuance of subpoenas known as requirement letters and, possibly, a court application for a compliance order. Litigation over the provision of such information is growing because taxpayers are increasingly resisting demands for voluminous information and documents (including, in some cases, clearly irrelevant or privileged documents) to be provided within short time frames. As a sign of its strategic focus over the next two years, CRA is having Justice lawyers advise tax auditors on accessing information from taxpayers.

The CRA is also looking to its treaty partners for exchange of information. The conclusion of a number of tax information exchange agreements between Canada and various jurisdictions, including tax havens, will facilitate further recovery of information.

Need for strategic management of tax controversies

In many tax disputes involving large amounts, particularly in the transfer pricing and aggressive tax planning areas, formal litigation in the Tax Court of Canada is becoming acrimonious, much to the displeasure of some judges who have, on occasion, been openly critical of a perceived decline in cooperation between counsel and parties to the proceedings.

If possible, taxpayers are looking for ways to avoid tax litigation through, for example, settlement conferences encouraged by the Tax Court or through attempts to resolve disputes at earlier stages of the tax controversy process, such as at the audit or administrative appeal stages. Statistics show that very few disputes are actually decided by judges of the Tax Court relative to the number of disputes settled at earlier stages of the tax controversy process.

Domestically, alternative dispute resolution mechanisms such as arbitration and mediation have enjoyed little or no success. However, in the international arena where double tax is at issue, taxpayers are attempting to find resolution through either or both the Mutual Assistance Procedure (including arbitration when available) involving the Canadian competent authority and the conclusion of advance pricing agreements in transfer pricing matters.

Initiatives to combat aggressive tax planning

The CRA has been scrutinising international cross-border arrangements, including those which involve claims for foreign tax credits. Interprovincial tax planning arrangements have also attracted challenges and have resulted in cases being decided by the provincial superior courts. Various arrangements have been subject to the application of the federal or provincial general anti-avoidance rules (GAAR) as the primary or secondary ground of attack. These arrangements include tax deferral using partnerships, tax sparing, foreign tax credit utilisation, shifting of tax attributes or losses to arm's length parties, leveraged donations and claims for artificial capital losses. Tax authorities are also relying on specific anti-avoidance rules as well as judicial concepts such as "sham" and "ineffective transaction" to deny tax benefits being otherwise available.

Some recent jurisprudence

In late 2010 to the middle of 2011, the Supreme Court of Canada granted leave to appeal in a number of tax cases. These include Glaxo, the first transfer pricing case to reach this level, and St Michael Trust Corp., which involves the principles to be applied to ascertain the residence of a trust for income tax purposes. The tax community also eagerly awaits the release of the Copthorne decision, the fourth from this court to deal with the interpretation of the GAAR but the first to apply the concept of "series of transactions " in the context of the term "avoidance transaction".

The Federal Court of Appeal, which hears appeals from the Tax Court and the Federal Court, decided two important decisions dealing with the GAAR (Collins & Aikman, Lehigh Cement) from which no further appeals will be heard. GE Capital Canada is a transfer pricing decision that upheld the taxpayer's ability to deduct a cross-border guarantee fee payable to a related party but suggested that "implicit support" is a factor to be considered in determining the creditworthiness of a subsidiary. In Bozzer, the Federal Court of Appeal provided a favourable interpretation for rules permitting waivers of interest, which may enable taxpayers to apply for discretionary relief to eliminate claims for arrears interest in broader circumstances.

The Tax Court has exclusive original jurisdiction to hear federal income tax and GST cases. It released decisions on topics such as the GAAR and international tax planning. These include Alberta Printed Circuits (transfer pricing), 4145356 Canada Limited (foreign tax credits), Potash Corporation (deductibility of professional fees in an international reorganization) and Triad Gestco (GAAR and the deductibility of capital losses).

The Queen's Bench of Alberta, a provincial superior court, released two interesting decisions (Husky, Canada Safeway) which rebuffed attempts by the tax administration of Alberta to apply provincial GAAR legislation to tax planning designed to minimize or eliminate Alberta income tax.

Ed Kroft, QC (ed.kroft@blakes.com) is a partner of Blake, Cassels & Graydon and leads the firm's tax controversy and litigation group.


François Barette

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Fasken Martineau DuMoulin LLP

The Stock Exchange Tower

PO Box 242, Suite 3700

800 Victoria Square

Montréal, QC H4Z 1E9

Canada

Tel: +1 514 397 5259

Fax: +1 514 397 7600

Email: fbarette@fasken.com

Website: www.fasken.com/francois-barette

François Barette is a partner in the litigation and taxation practices. He has an extensive tax litigation practice with expertise in federal and provincial income taxes, tax on capital and large corporations tax, sales tax, goods and services tax, payroll taxes and property taxes. His litigation practice also covers a wide range of civil and administrative matters.

François has represented such clients as foreign and Canadian corporations, partnerships, individuals and trusts in connection with domestic and international tax issues, administrative law issues and constitutional issues before the Supreme Court of Canada, the Federal Court of Appeal, the Federal Court of Canada, the Tax Court of Canada, the Québec Court of Appeal, the Québec Superior Court, the Court of Québec and various administrative tribunals.

François' expertise in federal and provincial income taxes includes issues of inter-provincial tax-planning arrangements, multi-jurisdictional taxation, retroactive tax legislation, general and specific anti-avoidance rules, and transfer pricing. He also has extensive experience in audits, compliance issues and objections.

Memberships and Affiliations

  • Québec Bar

  • Canadian Bar Association

  • Canadian Tax Foundation

  • Association de planification fiscale et financière

Rankings and Awards

  • Recognised by Best Lawyers for Tax (2009 & 2010 editions)

  • Achieved one of Martindale-Hubbell's highest ratings

Education

LLB, University of Montréal, 1979

Year of Call

Québec, 1980

Languages

French

English

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Thomas Boddez

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Thorsteinssons

PO Box 49123

Twenty-Seventh Floor, Three Bentall Centre

595 Burrard Street

Vancouver, BC V7X 1J2

Canada

Tel: +1 604 602 4260

Email: tmboddez@thor.ca

Website: www.thor.ca

Thomas Boddez is a partner of Thorsteinssons and a governor of the Canadian Tax Foundation. He has also served as managing partner. He received his LLB degree from the University of Toronto and his Bachelor of Commerce degree from the University of Alberta. He was admitted to the British Columbia Bar in 1993.

Thomas is a member of the Thorsteinssons tax litigation group, recently recognised for 2007 as the "Canadian Tax Litigation Firm of the Year" by International Tax Review.

Thomas' civil litigation practice includes representation of taxpayers in the audit and appeal processes with the Canada Revenue Agency (CRA), appeals to the Tax Court of Canada, Federal Court and provincial superior courts, and further appeals to the Federal Court of Appeal and Supreme Court of Canada. Thomas' criminal litigation practice focuses on tax evasion investigations, trials and appeals, including the conduct of voir dires to determine the admissibility of evidence in light of the Canadian Charter of Rights and Freedoms.

Litigation matters have included leading Supreme Court of Canada decisions on the reasonable expectation of profit test, and on the line between civil audits and criminal tax investigations, a successful class action seeking the recovery of interest improperly collected by the CRA and cases involving non-resident withholding taxes, the taxation of timber resource properties, foreign exchange gains, commodity trading, civil penalties, joint liability assessments and a variety of other tax issues. He has successfully negotiated favourable settlements in the majority of cases handled each year.

Thomas has lectured on taxation matters for the Canadian Tax Foundation, the Continuing Legal Education Society of British Columbia, the University of British Columbia, the Law Society Professional Legal Training Course, the Tax Executives Institute, the Institute of Chartered Accountants of British Columbia, the Certified General Accountants Association of British Columbia, the Asia Pacific Business & Law Institute, the British Columbia Medical Association and at numerous other conferences. He is the author of several articles on various aspects of taxation law.

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David Davies

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Thorsteinssons

PO Box 49123

Twenty-Seventh Floor, Three Bentall Centre

595 Burrard Street

Vancouver, BC V7X 1J2

Canada

Tel: +1 604 602 4252

Email: drdavies@thor.ca

Website: www.thor.ca

David Davies received his Bachelor of Commerce and LLB degrees from the University of British Columbia. He was admitted to the British Columbia Bar in 1989.

David's practice focuses primarily on planning and litigating tax shelter and quasi-tax shelter syndications involving partnerships (both general and limited), co-ownerships and joint ventures, having as few as one or two participants to as many as several thousand participants, concerning various income tax incentive provisions such as resource property exploration and development costs, depreciable assets with accelerated capital cost allowance, and deductible business expenses.

David has advised numerous clients in income tax planning matters who have required income tax disclosures in public and quasi-public securities offering documents.

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Ed Kroft, QC

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Blake, Cassels & Graydon

199 Bay Street

Suite 4000, Commerce Court West

Toronto, ON M5L 1A9

Canada

Tel: +1 416 863 2500

Fax: +1 416 863 2653

Email: ed.kroft@blakes.com

Website: www.blakes.com

Ed Kroft is a partner in the tax group and leader of the tax controversy & litigation group. He has appeared before the Supreme Court of Canada, the Tax Court of Canada, the Federal Court of Canada, the Federal Court of Appeal and the Supreme Court of British Columbia represents clients in tax disputes involving Canada Revenue Agency (CRA) and other tax authorities. He acts as counsel in tax cases and major transfer pricing disputes for large Canadian and multinational corporations. His many reported tax cases involve issues such as the general anti-avoidance rule, transfer pricing and interest deductibility.

Ed is a member of the rules committee of the Tax Court of Canada and a former governor of the Canadian Tax Foundation. Ed is consistently recognised as a leading lawyer in publications such as Chambers Global, World Tax, Legal Media Group's Guide to the World's Leading Transfer Pricing Advisers and the Lexpert/American Lawyer Guide to the Leading 500 Lawyers in Canada.

Ed is a past recipient of the Canadian Institute of Chartered Accountants Award for Excellence in Income Tax Practice and Education and was awarded an honorary CGA designation by the Certified General Accountants Association of British Columbia.

Ed has written more than 60 articles and papers on taxation and corporate law subjects for the Canadian Tax Foundation and other organisations. For over 20 years, he has been an adjunct professor in the Law Faculty at the University of British Columbia (UBC) and was the recipient of the Adam Albright Award for Outstanding Teaching. He is also the course director of the LLM course on tax administration and litigation at Osgoode Hall Law School (Toronto).

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Bill Maclagan

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Blake, Cassels & Graydon

595 Burrard Street

PO Box 49314

Suite 2600, Three Bentall Centre

Vancouver BC V7X 1L3

Canada

Tel: +1 604 631 3336

Fax: +1 604 631 3309

Email: wsm@blakes.com

Website: www.blakes.com

Bill Maclagan is a partner in the tax group. He is involved in all aspects of income and commodity taxation, including goods and services tax and transfer pricing. He practises in both the taxation planning and tax controversy areas. Bill represents clients at all stages of tax disputes involving Canada Revenue Agency and other tax authorities, including audit, appeals and litigation.

Bill is recognised as a leading lawyer in The Canadian Legal Lexpert Directory, The Best Lawyers in Canada and PLC Which Lawyer?.

Bill has written extensively in his area of expertise, has chaired conferences on general tax and corporate matters, and is a frequent lecturer at programs offered by the British Columbia Continuing Legal Education Society and others. Bill is past chairperson of the tax subsection of the Canadian Bar Association in British Columbia, and is a governor of the Canadian Tax Foundation.

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Douglas Mathew

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Thorsteinssons

PO Box 49123

Twenty-Seventh Floor, Three Bentall Centre

595 Burrard Street

Vancouver, BC V7X 1J2

Canada

Tel: +1 604 602 4291

Email: dhmathew@thor.ca

Website: www.thor.ca

Douglas Mathew received his BComm from the University of Alberta and his LLB (with honours) from the University of Toronto. He is a member of the Bars of British Columbia (1989) and Ontario (1992). Doug is also a chartered accountant (1980) who practised public accounting and worked in industry before attending law school.

Douglas' practice focuses on civil tax litigation, including appellate-level advocacy and appearing before the Tax Court of Canada and provincial superior courts. He also represents taxpayers in the appeal process with the Canada Revenue Agency (CRA) and provincial tax authorities. Litigation matters have included such issues as tax avoidance, transfer pricing, directors' liability, GST, capital tax, provincial sales tax and scientific research tax incentives. He has acted for a number of multi-taxpayer groups and syndicates in disputes with the CRA.

Douglas has been appointed by the minister of justice as a member of the editorial board of the Federal Court Reports with responsibility for taxation matters. He has served as an instructor for the Bar admission courses of the Law Societies of British Columbia and Upper Canada, as well as numerous tax conferences and seminars. He has also served as an executive of the Canadian Bar Association (Ontario) tax law section and is a member of the Taxation Professional Development Committee of the Institute of Chartered Accountants of British Columbia. He is a member of the Canadian Tax Foundation, the tax law sections of both the British Columbia and Ontario Bar Association and the International Fiscal Association.

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Janice McCart

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Blake, Cassels & Graydon

199 Bay Street

Suite 4000, Commerce Court West

Toronto, ON M5L 1A9

Canada

Tel: +1 416 863 2669

Fax: +1 416 863 2653

Email: janice.mccart@blakes.com

Website: www.blakes.com

Janice McCart is a partner in the tax group. Her focus is on matters of international tax controversy, and she is involved in all aspects of dispute resolution from pre-audit to litigation. Janice specialises in transfer pricing and for the past 30 years, has been representing Canadian, US and European multinationals before Canadian and foreign governments throughout the entire course of her practice, including competent authority and advance pricing agreement representations.

Janice is a past governor of the Canadian Tax Foundation, and serves as an editor on the foundation's permanent editorial staff. She is a member of the transfer pricing subcommittee of the Joint Committee on Taxation of the Canadian Bar Association, the Canadian Institute of Chartered Accountants, the transfer pricing subcommittee of the American Bar Association, the Taxation Committee of the US Council for International Business, the Canadian Bar Association and the International Fiscal Association. Janice has been a councillor of the International Fiscal Association (Canadian branch) since 2006 and was a member of the 2009 planning committee for the Annual Congress of the International Fiscal Association held in Vancouver in 2009. From 1996 to 2003, Janice was co-chair of the Toronto Centre Canada Customs and the Revenue Agency & Professionals Consultation Group. From 1982 to 1987, she was co-counsel to the Revenue Canada/Pharmaceutical Manufacturers Association of Canada Task Force.

Since 2000, Janice has been consistently ranked and named as a leading adviser in transfer pricing in three Legal Media Group publications: Guide to the World's Leading Transfer Pricing Advisers, The Best of the Best and World Tax, a supplement to International Tax Review. She was also named in the inaugural issue of World's Leading Women in Business Law and was recognised as a leading transfer pricing specialist in Chambers Global: The World's Leading Lawyers for Business 2011.

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Warren Mitchell, QC

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Thorsteinssons

PO Box 49123

Twenty-Seventh Floor, Three Bentall Centre

595 Burrard Street

Vancouver, BC V7X 1J2

Canada

Tel: +1 604 689 1261

Email: wjamitchell@thor.ca

Website: www.thor.ca

Warren Mitchell was educated at the University of British Columbia, from which he holds both Bachelor of Commerce and Bachelor of Law degrees. He was first admitted to the Bar of Alberta (1963) and has since been admitted to the Bars of British Columbia in 1966 and Ontario in 1990.

Warren served as a solicitor in the taxation division of the Department of National Revenue until 1965.

Warren's practice focuses on large case tax litigation. He has appeared as counsel in the provincial, trial and appellate divisions of British Columbia and Ontario, and in the Tax Court of Canada, Federal Court – Trial Division and the Federal Court of Appeal as well as the Supreme Court of Canada.

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Edward Rowe

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Blake, Cassels & Graydon

855 - 2nd Street SW

Suite 3500, Bankers Hall East Tower

Calgary, AB T2P 4J8

Canada

Tel: +1 403 260 9798

Fax: +1 403 260 9700

Email: edward.rowe@blakes.com

Website: www.blakes.com

Edward Rowe is a partner in the tax group. He provides tax advice on cross-border and domestic public take-overs, as well as corporate reorganisation and financing transactions, and resource tax matters. His tax practice also includes the settlement of tax disputes, including the general anti-avoidance rule (GAAR) assessments, with the Canada Revenue Agency, including competent authority, and he has acted as counsel in leading tax cases before all levels of courts.

Edward is a member of the bar of the provinces of Alberta and Ontario, and was a judicial clerk to the Honourable J Major of the Supreme Court of Canada in 1995. More recently, Edward served on Executive Interchange as a special adviser to the tax policy branch of the Department of Finance on matters related to resource tax and corporate reorganisations. Before joining Blakes in 2005, he was a tax partner with a major accounting firm.

Edward is a member of the International Fiscal Association and the Canadian Tax Foundation. He has authored a number of articles and conference presentations concerning domestic and international tax planning and tax litigation, and has taught international tax at the University of Ottawa Faculty of Law.

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Alan Schwartz, QC

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Fasken Martineau DuMoulin

333 Bay Street, Suite 2400

Bay Adelaide Centre, Box 20

Toronto, ON M5H 2T6

Canada

Tel: +1 416 865 4432

Fax: +1 416 364 7813

Email: aschwartz@fasken.com

Website: www.fasken.com/alan-schwartz

Alan Schwartz is a tax lawyer whose practice involves advising on corporate transactions such as acquisitions, corporate reorganisations, prospectus disclosure and the establishment of investment vehicles. A significant part of his practice includes pleading cases in tax courts at all levels from the Tax Court to the Supreme Court of Canada. Alan has been involved in leading tax cases on the general anti-avoidance rule, the existences of a separate business, partnership reorganisations, asset classification, residence of trusts and employment benefits, including the case of Savage v the Queen which was decided in favour of the taxpayer by the Supreme Court of Canada. He is also involved in advising on estate planning and trusts. Alan is the founder and editor-in-chief of the Carswell Tax Service, "GAAR Interpreted" which is a leading publication on the general anti-avoidance rule.

Alan joined the firm as an associate in 1970 and became a partner in 1976. He was appointed Queen's Counsel in 1985. He was elected managing partner of Fasken Campbell Godfrey in February 1994 and was the Toronto office's managing partner and national chair of Fasken Martineau DuMoulin until June 30 2001. Alan was the firm's national chair of the taxation group until August 2005.

Alan is rated by International Tax Review, Best Lawyers, Chambers, Lexpert and PLC as one of the leading tax lawyers in Canada.

Memberships and Affiliations

  • Ontario Bar Association

  • Canadian Bar Association

  • International Fiscal Association

  • Toronto Senior Tax Practitioners Study Group

Rankings and Awards

  • Recognized by Best Lawyers in Canada 2011 as a leading practitioner in tax law

  • Canadian Legal Lexpert Directory 2010: consistently recommended, litigation – corporate tax; repeatedly recommended, corporate tax

Education

AB, Princeton University, 1965

LLB, University of Toronto, 1968

Year of Call

Ontario, 1970

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Christopher Steeves

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Fasken Martineau DuMoulin

333 Bay Street, Suite 2400

Bay Adelaide Centre, Box 20

Toronto, ON M5H 2T6

Canada

Tel: +1 416 868 3401

Fax: +1 416 364 7813

Email: csteeves@fasken.com

Website: www.fasken.com/christopher-steeves

Christopher Steeves is a partner in the firm's taxation group with extensive experience in corporate restructurings and acquisitions involving Canadian businesses. Christopher advises clients on the income tax aspects of complex domestic and cross-border financings, and financial instruments including derivatives, securities lending and collective investment funds. He also has expertise with respect to transfer pricing and the successful resolution of disputes with Canadian tax authorities.

Christopher provides sophisticated tax advice in a practical manner. Christopher often works with his clients and their advisers outside Canada to develop innovative, tax-efficient means of accomplishing cross-border business objectives.

Christopher regularly speaks at industry conferences and seminars. He has been an instructor for the Canadian Bar Association's course Tax Law for Lawyers, "Cross-Border Tax Issues" since 2006, and has also taught a course on transfer pricing for the Institute of Chartered Accountants of Ontario since 2005. He is also a former instructor of the Faculty of Law at the University of Windsor (1999-2003).

Memberships and Affiliations

  • Secretary, Canadian Securities Lending Association

  • Chair, Taxation Committee, Canadian Securities Lending Association

  • Member, Canadian Tax Foundation

  • Member, International Fiscal Association

  • Member, Ontario Bar Association, Tax Law Section and Business Law Section

  • Member, Editorial Board, International Tax Newsletter, CCH Canadian Limited

  • Member, Editorial Board, Corporate Structures and Groups, Federated Press

Rankings and Awards

  • Recognized by Who's Who Legal as a leading specialist in corporate tax

  • Recognized by The Best Lawyers in Canada 2011 as a leading practitioner in tax law

  • Recommended by PLC Which Lawyer? 2011 as one of Ontario's pre-eminent tax lawyers

Education

LLB, Queen's University, 1992

BA, Queen's University, 1989

Year of Call

Ontario, 1994

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Craig Sturrock

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Thorsteinssons

P.O. Box 49123

Twenty-Seventh Floor, Three Bentall Centre

595 Burrard Street

Vancouver, BC V7X 1J2

Canada

Tel: +1 604 689 1261

Email: ccsturrock@thor.ca

Website: www.thor.ca

Craig Sturrock attended the University of British Columbia, obtaining his LLB degree in 1967. In 1968 he received his LLM degree from the Southern Methodist University in Dallas, Texas. He was admitted to the British Columbia Bar in 1969.

Craig is an author and speaker for the Canadian and British Columbia Bar Associations, the Continuing Legal Education Society of British Columbia and the Canadian Tax Foundation. He was also a former member of the board of governors of the Canadian Tax Foundation.

Craig's practice focuses primarily on civil and criminal tax litigation. He has appeared as counsel in both trial and appellate proceedings in the federal and provincial superior courts and before the Supreme Court of Canada. His litigation experience includes both federal and provincial taxation statutes, with particular reference to criminal litigation and the Charter of Rights.

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Paul Tamaki

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Blake, Cassels & Graydon

199 Bay Street

Suite 4000, Commerce Court West

Toronto, ON M5L 1A9

Canada

Tel: +1 416 863 2697

Fax: +1 416 863 2653

Email: paul.tamaki@blakes.com

Website: www.blakes.com

Paul Tamaki is a partner in the tax group. His practice covers all areas of taxation law, including mergers and acquisitions, reorganisations, corporate finance, structured asset finance, joint ventures, international tax and transfer pricing. He also acts for clients in administrative tax appeals and other representations to governments.

Paul is a frequent writer and speaker on tax matters. He is a past chair of the National Tax Section of the Canadian Bar Association and past co-chair of the Joint Committee on Taxation of the Canadian Bar Association and the Canadian Institute of Chartered Accountants. He has also been a governor and member of the executive committee of the Canadian Tax Foundation.

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Deborah Toaze

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Blake, Cassels & Graydon

595 Burrard Street

PO Box 49314

Suite 2600, Three Bentall Centre

Vancouver BC V7X 1L3

Canada

Tel: +1 604 631 5210

Fax: +1 604 631 3309

Email: deborah.toaze@blakes.com

Website: www.blakes.com

Deborah Toaze is a partner in the tax group and the tax controversy & litigation group. Her practice focuses on tax dispute resolution and transfer pricing. She represents taxpayers in tax disputes involving the Canada Revenue Agency (CRA) at the CRA audit and appeals stages and in Tax Court proceedings. Deborah's transfer pricing practice focuses on advising clients on the resolution of transfer pricing disputes and the impact of transfer pricing in the context of mergers and acquisitions. She also advises clients on tax avoidance matters including the avoidance of transfer pricing disputes.

Deborah joined Blakes in June 2010 from another major national law firm. Deborah has extensive experience in the taxation of financial institutions and financial products. She previously held tax positions in industry, including the position of vice-president of taxation at Scotiabank.

Deborah regularly writes on tax matters and speaks at various tax conferences and seminars. She is a chartered accountant and a member of the Canadian Bar Association and the Canadian Tax Foundation.

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Jeffrey Trossman

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Blake, Cassels & Graydon

199 Bay Street

Suite 4000, Commerce Court West

Toronto, ON M5L 1A9

Canada

Tel: +1 416 863 4290

Fax: +1 416 863 2653

Email: jeffrey.trossman@blakes.com

Website: www.blakes.com

Jeffrey Trossman is a partner in the Blakes tax group. His practice focuses on all aspects of income tax planning, including M&A, multi-jurisdictional corporate reorganisations and restructuring, private equity, international taxation and the taxation of income trusts, mutual funds, real estate investment trusts, and other investment vehicles.

Jeffrey has acted for a wide variety of public and private companies. He also has experience representing taxpayers at all levels in the tax appeal process under federal and provincial taxation statutes.

Jeffrey has written and spoken widely in the tax area. He has authored articles published by the Canadian Tax Foundation, Osgoode Hall Law School, International Tax Review and other Euromoney publications. He is an active member of the International Fiscal Association and the Canadian Tax Foundation. He is a member of the faculty for the 2007-2011 Institutes on Tax Aspects of Mergers & Acquisitions organised by the Penn State Dickinson School of Law and the New York City Bar Association, and also served as a country reporter for Canada at the 2008 Congress of the International Fiscal Association held in Brussels. He is also a member of the Committee on Taxation of Business Entities of the New York City Bar Association.

Jeffrey has been recognised as a leading tax practitioner in Legal Media Group's Guide to the World's Leading Tax Advisers 2010, PLC Cross-border Tax on Corporate Transactions Handbook 2007, Chambers Global: The World's Leading Lawyers for Business 2011, The Canadian Legal Lexpert Directory 2010, PLC Which Lawyer? 2011 and Law Business Research's Who's Who Legal: Canada 2010.

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Matthew Williams

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Thorsteinssons

PO Box 786

Thirty-Third Floor, Brookfield Place

Bay Wellington Tower, 181 Bay Street

Toronto, ON M5J 2T3

Canada

Tel: +1 416 864 9104

Email: mgwilliams@thor.ca

Website: www.thor.ca

Matthew Williams is a partner and practices in the firm's Toronto office. He received his BA from the University of Western Ontario and his LLB from the University of British Columbia.

Matthew's practice focuses on all aspects of taxpayer representation including civil and criminal tax litigation. He has appeared before the Tax Court of Canada, the Federal Court of Canada, the Federal Court of Appeal and the Ontario Superior Court of Justice on a wide range of issues including tax appeals, tax evasion matters, Canada Pension Plan/Employment Insurance appeals, Charter applications and rectification orders. Matthew is also the co-chair of the firm's student committee which is responsible for the recruitment, development and evaluation of summer and articling students at the firm.

Recently, Matthew acted as co-counsel in Canada's first treaty shopping case and is involved in a number of tax appeals dealing with a wide range of international, domestic and provincial tax issues.

Matthew has spoken at a number of conferences including the annual Ontario Tax Conference on the topic of adviser penalties and on the application of the general anti-avoidance rule; and has authored a number of articles including a paper on taxpayer's rights published by the Canadian Tax Journal.

A member of the Canadian Bar Association, the Canadian Tax Foundation, the Advocates Society and the Rocky Mineral Law Foundation, Matthew is also an editor of Tax Litigation Quarterly.

Matthew was recently named one of the 40 leading lawyers in Canada under 40 by Lexpert magazine.

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Tom Akin

McCarthy Tétrault

Neil Bass

Fraser Milner Casgrain

Jacques Bernier

Baker & McKenzie

Nat Boidman

Davies Ward Phillips & Vineberg

Donald Bowman

Fraser Milner Casgrain

Wendy Brousseau

McCarthy Tétrault

Alexandra Brown

Osler, Hoskin & Harcourt

Don Cherniawsky

Felesky Flynn

Chia-yi Chua

McCarthy Tétrault

Nicolas Cloutier

Davies Ward Phillips & Vineberg

Guy Du Pont

Davies Ward Phillips & Vineberg

Stephane Eljarrat

Davies Ward Phillips & Vineberg

Guy Gagnon

McCarthy Tétrault

Cheryl Gibson

Fraser Milner Casgrain

Natalie Goyette

Wilson & Partners

Gerald Grenon

Osler, Hoskin & Harcourt

Jean Groleau

Fraser Milner Casgrain

Jehad Haymour

Fraser Milner Casgrain

William Innes

Fraser Milner Casgrain

Andrew Kingissepp

Osler, Hoskin & Harcourt

Ian MacGregor

Osler, Hoskin & Harcourt

Carman McNary, QC

Fraser Milner Casgrain

Al Meghji

Osler, Hoskin & Harcourt

Joel Nitikman

Fraser Milner Casgrain

Cliff Rand

Stikeman Elliott

David Robertson

Ernst & Young

Stephen Ruby

Davies Ward Phillips & Vineberg

John Saunders

Wilson & Partners

Brian Segal

Baker & McKenzie

Ken Skingle

Felesky Flynn

David Smith

Davies Ward Phillips & Vineberg

David Spiro

Fraser Milner Casgrain

Curtis Stewart

Bennett Jones

Roger Taylor

Ernst & Young

John Yuan

McCarthy Tétrault

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The Dutch TP decree marks a turn in the Netherlands as the country aligns its tax policies with OECD standards over claims it is a tax haven.
Gorka Echevarria talks to reporter Siqalane Taho about how inflation, e-invoicing and technology are affecting the laser printing firm in a post-COVID world.
Tax directors have called on companies to better secure their data as they generate ever-increasing amounts of information due to greater government scrutiny.
Incoming amendments to the treaty could increase costs on non-resident Indian service providers.
Experts say the proposed minimum tax does not align with the OECD’s pillar two regime and risks other countries pulling out.
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