Recent Work
  • Canada v. Vaillancourt-Tremblay, an appeal related to income tax aspects of a corporate reorganization.
  • An independent petroleum refinery in the context of a highly complex matter involving the importation and sale of fuel in Canada and the application of Canadian commodity taxes (GST/HST, QST and fuel tax).
  • Copthorne Holdings Ltd. v. Canada, an appeal before the Supreme Court of Canada related to the GAAR.
  • A Canadian corporation in an appeal to the Tax Court of Canada involving the fair market value of shares transferred as part of a court-approved plan of arrangement.
  • A Canadian manufacturer in an audit by the Canada Revenue Agency involving proposed transfer pricing adjustments and penalties relating to the deductibility of interest.
  • A non-resident corporation in an appeal involving the application of the GAAR to dividends subject to Part XIII withholding tax.
  • A major North American retailer in relation with tax consequences of a Canadian cross-border acquisition structure that were challenged by the Canada Revenue Agency.
  • A large company managing loyalty programs in a judicial review of administrative decisions.
  • A large multinational retail company in an appeal related to the GAAR.
  • Multinational oil and gas companies in judicial reviews of Canadian tax authorities’ audit powers.
  • A multinational warranty service company in an appeal related to GST/HST.
  • A large printing company in several Canadian jurisdictions in appeals related to interprovincial allocation of income.
  • A multinational coffee company in an appeal related to the GAAR.
  • A large telecommunication company in an appeal related to the GAAR.
  • A car financial service company in an appeal related to Quebec capital tax.
  • A multinational coffee company in an appeal related to the GAAR and foreign tax credits.
  • An engineering company in an appeal related to SR&ED tax credits.