Recognized in:Tax Law
Law School:Dalhousie Law School
Location:100 King Street West1 First Canadian PlaceSuite 6200, P.O. Box 50Toronto, ON M5X 1B8
- Dalhousie Law School, LL.B
- Harvard Law School, LL.M
- University of Alberta, B. Sc
- Ontario, The Law Society of Upper Canada
- Alberta, Law Society of Alberta
- American Bar Association - Member
- Canadian Petroleum Tax Society - Member
- Canadian Tax Foundation - Member
- The Advocates’ Society - Member
Named "Lawyer of the Year" by Best Lawyers for:
- Tax Law, Toronto (2015)
Recognized in The Best Lawyers in Canada for work in:
- Tax Law
- Who’s Who Legal : Corporate Tax
- Expert Guides: The Legal Media Group Guide to the World’s Leading Lawyers : Transfer Pricing Advisers
- World Tax : Tax Litigation
- Lexpert Special Edition: Canada’s Leading Corporate Lawyers
- Lexpert Special Edition: Canada’s Leading Litigation Lawyers
- The Lexpert Guide to the Leading US/Canada Cross-border Corporate Lawyers in Canada : Corporate Tax
- The Lexpert Guide to the Leading US/Canada Cross-border Litigation Lawyers in Canada : Corporate Tax
- The Lexpert/American Lawyer Guide to the 500 Leading Lawyers in Canada : Corporate Tax; Corporate Tax Litigation
- The Canadian Legal Lexpert Directory : Corporate Tax and Corporate Tax Litigation (Most Frequently Recommended)
- Chambers Global: The World’s Leading Business Lawyers : Tax Litigation (Star Performer)
Areas of Expertise:
- The Queen v. GlaxoSmithKline Inc., 2012 SCC 52.
- The Queen v. General Electric Capital Canada Inc., 2010 FCA 344 – The first transfer pricing case in Canada to apply the modern transfer pricing regime set out in section 247 of the Income Tax Act (Canada), in addition to the regime set out in former subsection 69(2).
- TD Securities (USA) LLC v. The Queen, 2010 TCC 186 - Overturned the CRA’s long-standing policy of denying treaty benefits to US limited liability companies.
- Canada Trustco Mortgage Co. v. The Queen, 2005 SCC 54; 2004 DTC 6119 (F.C.A.) – GAAR did not apply to a sale-leaseback transaction.
- CIBC World Markets Inc. v. The Queen, 2011 FCA 270
- The Toronto-Dominion Bank v. The Queen, 2011 FCA 221– Capital loss held not artificial.
- The Queen v. 3850625 Canada Inc., 2011 FCA 117 – Decision is favourable for many resource business seeking a broad interpretation of the resource allowance rules.
- Cameco Corporation v. The Queen, 2011 TCC 636 and 2011 TCC 356- Successful motion to strike portion of the Crown’s pleadings.
- General Electric Capital Canada Inc. v. The Queen, 2010 TCC 490- The decision awarded the highest amount of costs ever by the TCC to the taxpayer.
- Imperial Oil Resources Ltd. V. Canada (Attorney General), 2009 FCA 325 – Interpretation of remission orders.
- Alberta Power (2000) Ltd. v. The Queen, 2009 TCC 412 – Taxpayer successfully treated lump sum payment of $59.7 million as a capital receipt and not an income receipt.
- Alcatel 2005 TCC 149.
- Gifford v. The Queen, 2004 SCC 15 – Interest expense is current expense to moneylenders.
- The Queen v. Imperial Oil of Canada Limited, 2004 DTC 6044 (F.C.A.) – GAAR did not require amount of taxpayer loans to bank subsidiaries to be included in large corporations investment allowance.
- Imperial Oil Limited v. The Queen, 2004 DTC 2377 (T.C.C.) – Deductibility of foreign exchange loss under paragraph 20(1)(f).
- Petro Canada v. The Queen, 2004 FCA 158 – Tax treatment of outlays in respect of seismic.
- General Motors of Canada Limited v. The Queen, 2004 FCA 370 and 2003 DTC 153 (T.C.C.) – Tax treatment of contingent liabilities.
- The Queen v. Imperial Oil Limited and Inco Limited, 2003 DTC 5485 (F.C.A.) – Taxpayer has right to appeal 90 days following objection.
- Placer Dome Canada Limited v. Minister of Finance of Ontario, 61 O.R. (3d) 628 (Ont. Sup. Ct.) – Taxation of hedging gain under Ontario Mining Tax Act.
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