Andrew Boyd, Toronto

About Andrew

Andrew is an accomplished tax litigator with extensive experience in handling complex trial and appellate matters. His practice focuses on navigating high-stakes tax disputes for corporate clients.

Over the course of his career, Andrew has represented clients in a wide range of contentious income tax and indirect tax matters as well as procedural disputes. He has appeared in a variety of significant cases, representing some of Canada's largest corporate taxpayers.

In addition to his litigation practice, Andrew advises clients throughout the audit and administrative appeals process, offering practical guidance on resolving high-risk disputes efficiently while positioning matters effectively for litigation.

Select Experience

Andrew has worked on a broad range of tax disputes, including:

The application of transfer pricing rules to guarantee fee payments, manufacturing and distribution agreements, settlement payments and supply agreements
The application of the federal and provincial GAARs to tax planning arrangements
Attempts to compel the disclosure of sensitive tax positions at audit
Reassessments issued beyond the ordinary limitation period on the basis of alleged misrepresentations attributable to neglect
Allegations of sham, window dressing and legal ineffectiveness
Identification of the “true supplier” for GST/HST purposes and whether sufficient information was retained to claim input tax credits
The characterization of rewards (points) services for purposes of GST/HST
Input tax credit entitlement with respect to capital improvements
Allegations the taxpayer failed to object within 90 days, in circumstances where no reassessments had been received
Whether two transactions were part of the same series
The characterization of shares as excluded property for purposes of the Foreign Accrual Property Income (FAPI) rules
CRA audits of high-net-worth individuals
Audits involving international tax issues

Professional Activities

Andrew has served on the Steering Committee of the Canadian Tax Foundation’s Young Practitioners Program (Toronto) for four years, where he organized and moderated presentations on developments in tax litigation. He has acted as a Member-at-Large in the Advocates’ Society (Tax Litigation Practice Group), and is a member of the Law Society of Ontario, the Ontario Bar Association, the Canadian Bar Association and the Canadian Tax Foundation. Andrew also served as an adjunct lecturer (Bowman Tax Moot Coach) at the University of Toronto since 2022.