Areas of Expertise
Representative Work
- Assisted a tech company in challenging a large tax liability assessed by the IRS following a major transaction
- Assisted a trustee of a foreign trust in a complex U.S. Tax Court litigation
Latest Insights
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Report Dec 5, 2024
CRA’s power to audit and assess: new developments, old problems
Proposed statutory amendments grant the Canada Revenue Agency more discretionary power.
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Osler Update May 8, 2024
Even the dead wouldn’t be spared from Canada’s capital gains hike
Canada’s proposed increase to its capital gain inclusion rate is likely to impact a wide cross-section of taxpayers, not just the...
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Osler Update Dec 11, 2023
A new era for the Canadian GAAR
Canada’s general anti-avoidance rule (GAAR) operates to negate tax benefits arising from “abusive” tax avoidance transactions.
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Media Mentions
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Dec 20, 2024
Canada audit proposal would bring big noncompliance consequences – Bloomberg Tax
Canada’s proposal to expand the discretionary power of the Canada Revenue Agency (CRA) could influence how audits are conducted and taxpayers’...
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Media Mentions Nov 20, 2023
Amendments to GAAR: The new presumption and penalty exception – Canadian Tax Focus
Two new key features of GAAR introduced by the federal government in draft legislation in August are potentially here to stay.
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Speaking and Writing
Published Work
- “New Powers, New Challenges: Judicial Review of Expanding CRA Tax Audit Powers”, Tax Litigation, Volume XXVII No. 4, 2024
- “Canada Audit Proposal Would Bring Big Noncompliance Consequences”, Bloomberg Tax, December 16, 2024 (with Pooja Mihailovich)
- “Implications of the Notice of Non-Compliance and the Compliance Order Penalty”, Canadian Tax Focus, 14:3, August 2024 (with Roger Smith)
- “Amendments to GAAR: The New Presumption and Penalty Exception”, Canadian Tax Focus, 13:4, November 2023
Credentials
Education
- New York University School of Law, LL.M., International Tax Law
- University of British Columbia, J.D.
- University of British Columbia, B.Sc. (Biology)
Languages
- English
Professional Affiliations
- Canadian Bar Association
- Canadian Tax Foundation
- Law Society of Ontario
- New York State Bar Association
- New York City Bar Association