Andrew specializes in taxation with a focus on dispute resolution at the audit and notice of objection levels (this includes transfer pricing) and also tax litigation. Andrew has written and presented papers on a number of income tax subjects at various seminars and conferences. He is the Canadian correspondent for the Journal of International Taxation and has written extensively for that publication and others. Andrew has also presented on income tax issues at various conferences and seminars.
Representative Work
- Cameco Corporation
Cameco Corporation in its successful dismissal of CRA appeal by the Supreme Court of Canada
- Representing numerous clients in large income tax disputes at both the audit and appeals levels, at both the federal and provincial levels and at Competent Authority
- Representing numerous clients in disputes involving the Canada Revenue Agency GAAR Committee at the audit and appeals level
- Advising numerous clients on their rights regarding access by Canada Revenue Agency to confidential documents, including accounting working papers, and advising on the scope of privilege and other available means to protect confidentiality (this included advice to leading financial institutions in recent litigation over requirements relating to unnamed third persons)
- Advising numerous clients on their rights in obtaining information from the Canada Revenue Agency
- Representing numerous clients in submissions to the Canada Revenue Agency’s Transfer Pricing Review Committee and in other transfer pricing matters, including appeals and competent authority representation
- Representing clients in seeking legislative relief from the Department of Finance
Cameco Corporation in its successful dismissal of CRA appeal by the Supreme Court of Canada
- Advising numerous clients on their rights in obtaining information from the Canada Revenue Agency
- Representing numerous clients in submissions to the Canada Revenue Agency’s Transfer Pricing Review Committee and in other transfer pricing matters, including appeals and competent authority representation
- Representing clients in seeking legislative relief from the Department of Finance
Latest Insights
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Osler Update Jun 29, 2020
Federal Court of Appeal dismisses Crown’s appeal in Cameco
The Federal Court of Appeal upheld the Tax Court’s decision that Cameco’s transactions with its Swiss subsidiary were on arm’s length terms...
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Awards and Recognition
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The Canadian Legal Lexpert Directory: Recognized in Corporate Tax
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Best Lawyers in Canada: Recognized in Tax Law
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International Tax Review: Recognized in Tax Controversy; Transfer Pricing; Highly Regarded lawyer
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World Transfer Pricing: Recognized as a Highly Regarded lawyer
Media Mentions
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Osler News Aug 25, 2023
Osler recognized as a Tier 1 firm in ITR’s World Tax Guide 2024
Osler is proud to once again be recognized as a Tier 1 firm in the 2024 edition of the International Tax Review’s World Tax guide. Additionally, 19...
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Osler News Oct 4, 2021
Osler recognized as a Tier 1 firm in ITR’s World Tax Guide 2022
Osler has maintained its Tier 1 rankings in ITR’s World Tax Guide with 18 lawyers recognized as leaders in their field.
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Osler News May 12, 2021
Osler’s National Litigation team recognized at the Benchmark Canada Awards 2021
Osler is proud to announce that our National Litigation team has been recognized at the 2021 Benchmark Canada Awards.
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Osler News Sep 29, 2020
Osler earns Tier 1 rankings in ITR’s 2021 World Tax Guide
Osler is proud to announce we have once again been recognized in Tier 1 of International Tax Review’s World Tax Guide 2021, earning top rankings in...
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Speaking and Writing
Speaking Engagements
Managing Transfer Pricing Audits and Disputes
Speaker, Toronto, January 14, 2020
Osler Tax Seminar & Webinar: Recent Developments in Tax Legislation and Case Law
Speaker, Recent Developments in Tax Litigation and Case Law, Toronto, October 5, 2016
Published Work
- “Implications of the OECD Business Restructuring Guidelines for Canadian Transfer Pricing Audits”, 16th Annual Transfer Pricing Conference, Infonex, March 6-7, 2012
- “Privilege Update – Trilogy of Canadian Cases Confirms the Functional Approach”, Journal of International Taxation, April, 2012
- “Protecting Privileged Documents”, 14th Managing Tax Audits & Investigations Course, Federated Press, May 14-15, 2012
- “Taxpayer Access to Government Papers and Government Access to Taxpayer Papers” (paper), “Access to Information During Tax Audits” (presentation), Tax Compliance: Administration and Dispute Resolution Conference, Canadian Tax Foundation, June 6-7, 2012
- “Transfer Pricing Audits”, 8th Understanding Canada/U.S. Transfer Pricing Course, Federated Press, Nov. 5-6, 2012
- “Protecting Privileged Documents”, 16th Managing Tax Audits & Investigations, Federated Press, June 13-14, 2013
- “Recent Developments in Managing Income Tax Audits and Appeals”, Client Seminar, February 27, 2014
- “Managing Canadian Large Corporations Appeals”, Journal of International Taxation, December, 2014.
- “Managing Appeals from Income Tax Reassessments”, Toronto Young Practitioners Group Meeting, Canadian Tax Foundation, April 14, 2015
Credentials
Education
- Osgoode Hall Law School, LL.B.
Languages
- English
Professional Affiliations
- Canadian correspondent for Journal of International Taxation
- Canadian Petroleum Tax Society
- Canadian Tax Foundation
- International Fiscal Association
- Member of Toronto Centre Tax Professionals Working Group
