Elena Balkos, Toronto

About Elena

Elena's practice involves advisory, planning and dispute resolution services in all areas of sales, customs and commodity tax, including GST/HST, provincial sales taxes (such as PST and QST), land transfer tax, excise taxes and tariffs. Her practice also involves advising clients on the structuring of import/export arrangements, customs duties, valuation methodology and tariff classification.

With a commitment to delivering practical, business-oriented advice, Elena advises clients across diverse industries such as real estate, e-commerce, healthcare, manufacturing, software and financial services. Her expertise supports businesses in mergers and acquisitions, establishing or expanding operations in Canada, navigating the complexities of indirect tax and customs compliance, mitigating risks, and identifying opportunities for cost savings and tax efficiency.

Elena also has extensive experience representing clients throughout the tax dispute resolution process — from initial audits and voluntary disclosures to formal objections and litigation. She advocates before the Canada Revenue Agency (CRA), Canada Border Services Agency (CBSA), provincial tax authorities and the Tax Court of Canada, providing strategic, results-driven counsel to resolve tax assessments.

Select Experience

Recent representative matters include advising:

M&A

Northview Fund in its C$742-million acquisition of three multi-family portfolios with properties in Alberta, Ontario, Nova Scotia and Quebec
The appliance business purchaser in the cross-border Chapter 11/CCAA recognition proceedings of Instant Brands Group
The purchaser in the cross-border Chapter 11/CCAA recognition proceedings of David's Bridal
A real estate fund and its land transfer tax obligations on a cross-Canada portfolio reorganization

Dispute Resolution

A large multinational recover over C$4-million in tax paid in error
A real estate developer in reducing a proposed GST/HST assessment by C$1.5-million
A retailer in resolving a customs (HS) classification dispute, lowering the tariff rate from 6.5% to 0%
A cosmetics company in resolving a GST/HST audit and zero-rated supplies, resulting in a no change assessment
A financial services company in resolving a GST/HST audit relating to place of supply rules, agency relationships and input tax credits, with minimal adjustments
A chemicals company in resolving an objection relating to uncollected GST/HST, in full
A real estate company in resolving an input tax credit (ITC) dispute at the Tax Court of Canada, achieving an almost complete recovery
A construction company in resolving an assessment for uncollected GST/HST revolving around an agency relationship at the Tax Court of Canada, in full