OVERVIEW & EXPERTISE

 
"Top-tier national tax practice with offices in Toronto, Montréal, Calgary and Vancouver. Highly sought after for its experience in transactional planning, including a high volume of M&A activity, much of it cross-border. Also known for its diversity of practice, with impressive capabilities in transfer pricing and commodity tax issues, as well as tax controversy."
Chambers Canada: Canada's Leading Lawyers for Business 2018

 

The Canada Revenue Agency (CRA) has been scrutinizing international cross-border arrangements, revising its tax audit policies, and conducting more transfer pricing and “aggressive tax planning” investigations. It is also using its powers under the Income Tax Act (ITA) to compel delivery of both domestic and foreign-based tax information. Businesses operating both in Canada and internationally are facing heightened regulation and disclosure requirements that are impacting their transactions, trade and business dealings.

Our Tax Controversy & Litigation group advises clients on all stages of the dispute process, from the start of the audit to the assessment and on to potential litigation. An important element in achieving results outside a courtroom is advance planning and the early involvement of our tax professionals. Blakes provides effective and aggressive representation that, in many cases, leads to a satisfactory resolution without the need for litigation.

We have a long history of representing foreign and Canadian-based clients at all levels within the CRA and in controversies involving international tax and transfer pricing disputes. Our tax controversy team has presented cases before various Canadian courts, including the Tax Court of Canada, the Federal Court of Appeal, the Supreme Court of Canada and various provincial courts.

Companies facing tax controversies retain Blakes because of our record of success in resolving contentious tax-related controversies. With unique expertise in emerging areas of controversy, including General Anti-Avoidance Rules (GAAR) cases, CRA demands for information from third parties and transfer pricing disputes, our lawyers are consistently recognized and ranked as leaders in global tax and business publications. For the fifth consecutive time, Blakes was named "Tax Firm of the Year" for Canada. The Firm was also awarded "North America Tax Disputes Firm of the Year" for the second consecutive time and "Canada Tax Disputes Firm of the Year" for the first time.

Blakes advises clients at all stages of the dispute process, from the start of the audit through assessment and on to potential litigation. Taking a proactive, client-focused approach, we provide effective and aggressive representation often without the need for litigation. When resolution is not possible at the administrative audit or appeals level, our litigation team applies its trial skills, capably representing clients before Canadian courts from the Tax Court to the Federal Court of Appeal and all the way up to the Supreme Court of Canada, when necessary.

Our specialized national team of taxation professionals has extensive experience in matters such as claims for privilege and demands for information by tax authorities. We regularly represent clients in federal and provincial tax disputes involving income taxes, commodity taxes, goods and services tax, harmonized sales tax, customs, excise taxes, tariffs, capital taxes and payroll taxes. Our team has dealt with such issues as the federal or provincial GAAR, abusive tax avoidance, transfer pricing, competent authority matters and advanced pricing arrangements.

Our lawyers are actively involved in the tax controversy field and are members of such organizations as the International Fiscal Association and the Canadian Tax Foundation. They have also served on other committees involving officials from federal and provincial tax authorities.


Representative Matters

  • HSBC Bank Canada v. Her Majesty The Queen, 2010 TCC 462
  • Husky Oil Limited v. Her Majesty The Queen, 2010 FCA 125
  • McKesson Canada Corporation v. Her Majesty The Queen, Tax Court of Canada Court No. 2008-2949 (IT)G
  • Spruce Credit Union v. The Queen, Tax Court of Canada Court No. 2009-3121 (IT)G
  • Finning International v. The Queen, Tax Court of Canada Court No. 2011-3430(IT)G
  • GTE Venezuela s.a.r.l. v. Her Majesty The Queen, Tax Court of Canada Court Nos. 2010-1553(IT)G, 2010-1552(IT)G, 2010-1551(IT)G
  • Aecon Construction Group Inc. v. Her Majesty The Queen, Tax Court of Canada Court No. 2010-3531 (IT)G
  • Canadian Air Crane v. Her Majesty The Queen, Tax Court of Canada Court No. 2011-950(IT)G
 

 PEOPLE

 
Page: 1 of 2       1 2        Items per page: 25 | 50 | ALL
Partner | Calgary
Calgary: 403-260-9775
Areas of Expertise: Tax, Tax Controversy & Litigation
Partner | Montréal
Montréal: 514-982-4117
Areas of Expertise: Tax, Tax Controversy & Litigation, Mergers & Acquisitions, Venture Capital, Technology, Private Equity, Life Sciences, Aviation/Aerospace, Cannabis, Emerging Companies & Venture Capital
Partner | Calgary
Calgary: 403-260-9656
Areas of Expertise: Construction Dispute Resolution, Product Liability, Intellectual Property, Tax Controversy & Litigation, Oil & Gas, IP Litigation, Construction
Associate | Montréal
Montréal: 514-982-4294
Areas of Expertise: Tax, Tax Controversy & Litigation
Partner | Toronto
Toronto: 416-863-2367
Areas of Expertise: Tax Controversy & Litigation
Associate | Vancouver
Vancouver: 604-631-3326
Areas of Expertise: Tax Controversy & Litigation, Tax
Partner | Montréal
Montréal: 514-982-5025
Areas of Expertise: Tax, Tax Controversy & Litigation, Africa, Private Equity, Mining, Plan Nord, Mining Streaming & Royalties
Partner | Toronto
Toronto: 416-863-5849
Areas of Expertise: Corporate Litigation, Tax Controversy & Litigation, Class Actions, Privacy, Freedom of Information, Media & Defamation, Constitutional & Charter of Rights, Business Crimes, Investigations & Compliance, Cybersecurity and Data Breach Response & Litigation, Construction Dispute Resolution, Cybersecurity
Associate | Calgary
Calgary: 403-260-9725
Areas of Expertise: Tax, Tax Controversy & Litigation
Partner | Toronto
Toronto: 416-863-2938
Areas of Expertise: Class Actions, Constitutional & Charter of Rights, Corporate Litigation, Tax Controversy & Litigation, Brownfields Redevelopment, Chemical & Waste Regulation, Environmental Assessment & Approvals, Environmental Litigation & Enforcement, Communications, Food, Beverage & Agribusiness, Manufacturing, Mining, Mining Streaming & Royalties, Environmental Litigation & Enforcement, Litigation & Dispute Resolution, Class Actions, Constitutional & Charter of Rights, Corporate Litigation, Cannabis, Environmental, Aboriginal
Partner | Calgary, Vancouver
Calgary: 403-663-2825
Vancouver: 604-631-3317
Areas of Expertise: Tax, Tax Controversy & Litigation
Partner | Vancouver, Calgary, Toronto
Vancouver: 604-631-5200
Calgary: 403-260-9699
Toronto: 416-863-2500
Areas of Expertise: Tax, Tax Controversy & Litigation, Transfer Pricing
Partner | Montréal
Montréal: 514-982-5030
Areas of Expertise: Tax, Tax Controversy & Litigation, Mergers & Acquisitions, Private Equity, Pension Funds Investment, Investment Products & Asset Management, Mining
Office Managing Partner | Vancouver
Vancouver: 604-631-3336
Areas of Expertise: Tax, Tax Controversy & Litigation, Transfer Pricing, Sales & Commodity Taxes, Pensions & Benefits, Executive Compensation, Forestry, Infrastructure, Middle East, Aboriginal
Associate | Calgary
Calgary: 403-260-9631
Areas of Expertise: Tax Controversy & Litigation, Tax, Energy, Mergers & Acquisitions, Corporate & Commercial
Senior Counsel | Toronto
Toronto: 416-863-2669
Areas of Expertise: Tax, Tax Controversy & Litigation, Transfer Pricing, Life Sciences
Partner | Toronto
Toronto: 416-863-3898
Areas of Expertise: Tax, Tax Controversy & Litigation, Pension Funds Investment, Investment Funds, Investment Vehicles
Associate | Toronto
Toronto: 416-863-2756
Areas of Expertise: Corporate Litigation, Constitutional & Charter of Rights, Arbitration, Product Liability, Tax Controversy & Litigation
Associate | Toronto
Toronto: 416-863-4024
Areas of Expertise: Tax, Tax Controversy & Litigation
Partner | Toronto
Toronto: 416-863-4274
Areas of Expertise: Litigation & Dispute Resolution, Media & Defamation, Business Crimes, Investigations & Compliance, Constitutional & Charter of Rights, Competition Litigation, Tax Controversy & Litigation, Arbitration, Cybersecurity and Data Breach Response & Litigation, Enterprise Risk & Crisis Response, Government & Public Sector, Mining Litigation & Dispute Resolution, Defence
Partner | Toronto
Toronto: 416-863-3187
Areas of Expertise: Tax, Transfer Pricing, Tax Controversy & Litigation
Partner | Toronto
Toronto: 416-863-2457
Areas of Expertise: Tax, Tax Controversy & Litigation, Investment Products & Asset Management, Government & Public Sector
Senior Counsel | Toronto
Toronto: 416-863-2697
Areas of Expertise: Tax, Tax Controversy & Litigation, Structured Finance & Derivatives, Asset-Based Finance
Partner | Vancouver
Vancouver: 604-631-5210
Areas of Expertise: Tax Controversy & Litigation, Tax, Transfer Pricing
Partner | Toronto
Toronto: 416-863-4290
Areas of Expertise: Tax, Tax Controversy & Litigation, Pension Funds Investment, Investment Funds, Investment Vehicles
Page: 1 of 2       1 2        Items per page: 25 | 50 | ALL