Ranked as leading Canadian Tax Controversy professional by the International Tax Review, with background in legal research and writing, dispute resolution and litigation, including significant experience with:
Advising on domestic and international income tax and GST/HST, and occasionally other provincial taxes including land transfer tax and tobacco tax;
Successfully resolving tax disputes at the audit and objection stages and through hearings before the Tax Court of Canada, including matters involving the general anti-avoidance rule, proceeds of crime, directors’ liability, GST/HST and provincial taxes, foreign accrual property income, the thin capitalization rules, shareholder benefits, inventory valuation, scientific research and experimental development tax credits, the taxation of partnerships and more; and
Rectification applications, Federal Court applications, voluntary disclosures and fairness applications to the Canada Revenue Agency.
Experience
2007 to present
Gowling Lafleur Henderson LLP – Tax and tax dispute resolution
2006 / 2007
Lerners LLP – Tax and tax dispute resolution
2005 / 2006
Tax Court of Canada – Articling student / Judicial clerkship
2000 / 2004
Banff Centre for the Arts – Fellowship and Summer Program Director
1997 / 2000
Ocean Way Recording and Cello Studios, Los Angeles, CA – Multi-platinum and Grammy Award winning recording engineer
Education
2011
Osgoode Hall Law School – LL.M. in Tax Law
2005
Osgoode Hall Law School – JD (Intensive Program in Tax Law)
1996
McGill University – M. Mus.
1993
St. Francis Xavier University – B. Mus.
Other:
CICA In-Depth Tax Course Parts I & II (2008/2009) & GST/HST Course (2012)
Osgoode Intensive Trial Advocacy Workshop (2009)
OBA Tax Law for Lawyers (2008)
Professional Memberships
Law Society of Upper Canada
The Advocates’ Society
Canadian Tax Foundation
Ontario Bar Association – Tax Section Executive Committee
Select Publications and Presentations
Non-Criminal Penalties under the Income Tax Act, Proceedings of the 2013 CTF Ontario Regional Conference, October 29, 2013 (with Michael Belz of Deloitte LLP)
Jarvis Principles Under Siege in Piersanti v The Queen, OBA Tax Section Newsletter, October 3, 2013, Vol. 13, No. 7
Reverse Auditing: Accessing the CRA’s Records Pertaining to Taxpayers, OBA Tax Section presentation, November 7, 2013
Protecting Tax Accrual Workpapers – Revisited … Again …, BorderCrossings Newsletter Vol. 6, no. 2 - October 2013 (with Paula Deighton of KPMG LLP)
A Comprehensive Discussion of Penalties – 2013 Prairie Provinces Tax Conference, Canadian Tax Foundation, Edmonton, Alberta, May 26, 2013 (with Dustin Burbank of E&Y LLP)
The CRA’s New and Aggressive Tax Enforcement Powers and How Taxpayers Can Protect Themselves, Federated Press International Tax Planning Journal, Vol. 18, No. 4, 1270 to 1274
Guindon, Third Party Penalties Revisited – Canadian Tax Journal, Volume 61, No. 2
Policies, Penalties and Tax Dispute Resolution – Ontario Bar Association presentation, London, Ontario, May 2013
Canadian Non-Resident Trust Rules – Case Studies, Carswell BorderCrossings Newsletter, Vol. 6, No. 1, April 2013
Audit Inquiry Letters and FIN 48 Advice: The Tip of the Iceberg, Ontario Bar Association presentation and paper, December 2012
Voluntary Disclosure and Taxpayer Relief - Canadian Tax Foundation presentation, September 2012
Executor Liability: Dealing with Historic Tax Non-Compliance in Canada and the United States, Carswell BorderCrossings Newsletter, Vol. 5, No. 2, July 2012 (with Paula Deighton of KPMG)
To Fight or Not to Fight – To Pay or Not to Pay: Factors to Consider When Dealing With Tax Assessments, CA Magazine, May 2012
Tax Court of Canada 2011 Canadian Tax Foundation Update, OBA Tax Section Newsletter, Vol. 22, No. 2, June 2012
The Federal Court of Appeal Settles Some Settlement Questions?, Canadian Tax Foundation Journal, Volume 60, No. 1, 2012
Director’s Liability: Execution Against Primary Debtor, Canadian Tax Highlights, Vol. 20, No.3, March 2012
Lack of Disclosure Fatal to Government’s Case, Canadian Tax Focus (February 2012)
Extended Reassessment Period for Transactions with Non-Arm’s Length Non-Residents, Ontario Bar Association Taxation Newsletter, Vol. 21, No. 2, April 2011
TCC Settlements, Canadian Tax Highlights, Vol. 19, No. 3, March 2011
If There’s Smoke, Is There Fire?, CA Magazine, March 2011
Move Quickly on Voluntary Tax Disclosure, Law Times, November 8 2010
Is the Minister a Proper Party to a Rectification Application?, Canadian Tax Journal, (2009), Vol. 57, No. 4
Lang v. M.N.R., The New Handbook for Determining a Worker’s Status as an Employee or Independent Contractor, Canadian Tax Journal, (2008), Vol. 56, No. 1
The Use of Special Purpose Trusts, Proceedings of the 59th Annual Canadian Tax Foundation Conference, 2007 CR p.35:1
Alternative Basis for Reassessments and Waivers, Ontario Bar Association Taxation Newsletter, Vol. 18, No. 1, 2007
The Use of Technical Notes in Statutory Interpretation, Tax Litigation, Vol. XIV, No. 1, 2006
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