Angelo Gentile

• Recognized in Chambers Canada as a top practitioner in Indirect Tax
• Recognized in The Best Lawyers in Canada in the field of Tax Law
• Recognized in The Canadian Legal Lexpert Directory in the areas of Corporate Tax, Commodity Tax/Customs and Litigation - Corporate Tax
• Consistently recognized by International Tax Review as an Indirect Tax Leader
• Recognized in Lexpert's Special Editions on Litigation and Finance + M&A
• Recipient of the 2016 Normand Guérin Award for his outstanding contribution to the study of commodity taxation

Memberships

• Canadian Bar Association (Commodity Tax Customs and Trade Section) 
• GST Leaders Forum, a group established by the CPA of the most prominent GST/HST accountants and lawyers from across Canada
• Canadian Tax Foundation
• Law Society of Ontario
• Ontario Bar Association

Community Involvement

• Advisor/Mentor, Pro Bono Students Canada/Tax Court of Canada Pro Bono Project

Represented multiple produce companies in connection with a hybrid sale of shares and assets for more than $100 million.

Represented an international media company in its acquisition of Canadian online film and television streaming assets.

Represented Powerfleet, Inc. (Nasdaq: AIOT), a global AIoT SaaS provider, in its acquisition and related financing of Fleet Complete, a leader in connected vehicle technology and fleet management. 

Acted for Knightstone Capital Management in the sale of a 20 per cent equity share in the CampusOne residence in Toronto.

Advised Phillips Foods Inc., a U.S.-based global processor and distributor of branded seafood products, in the acquisition of the assets of South Shore Seafoods Group of Companies, a Canadian seafood processor and distributor.

Represented Linamar Corporation in its acquisition of Bourgault Industries Ltd., a leading agricultural equipment manufacturer, for $640 million. In conjunction with the Bourgault transaction closing, Linamar also finalized a new $700-million term loan agreement.

Represented Melchior Management 777 Corporation, a property management service company, with the formation of M Commercial REIT, a new private commercial real estate investment trust, and the related vend-in of a portfolio of commercial properties located in Barrie, Ontario.

Advised Allied Properties Real Estate Investment Trust, a leading operator of distinctive urban workspace in Canada’s major cities, in the sale of its network-dense urban datacentre portfolio to Japanese telecommunications provider KDDI Corporation for $1.35 billion.

Advised the Ontario Ministry of Economic Development, Job Creation and Trade on all aspects of its winning bid for Volkswagen’s first overseas gigafactory, a several-billion-dollar investment that is one of the largest in Canadian history.

Acted as Ontario counsel to Premier Parks LLC in connection with EPR Properties’ US$142-million acquisition of the Village Vacances Valcartier resort and hotel in Quebec City and Calypso Waterpark in Ottawa, Ontario, and the simultaneous leasing of the properties to Premier Parks. 

Represented a leading global transportation industry manufacturer and supplier as Canadian counsel in its purchase of certain assets of a cross-border privately-owned commercial vehicle, bus and trailer manufacturing business.

Counsel to a confidential financial services client in a GST/HST Tax Court appeal settled in March 2022, in respect of an assessment of tax on services that were subsequently agreed to be GST/HST-exempt financial services.

Counsel to several confidential real estate clients in GST/HST Tax Court appeals and objections to the CRA Appeals Division, in respect of assessments pertaining to the GST/HST self-assessment of newly constructed residential rental buildings and the related new residential rental property rebates.

Counsel to Mr. Jefferson in Jefferson v. The Queen, 2019 TCC 91.

Counsel to Montecristo Jewellers Inc. in Montecristo Jewellers Inc. v. The Queen, 2019 TCC 31.

Counsel to Medallion Corporation in Medallion Corporation v. The Queen, 2018 TCC 157.

Counsel to Mr. Bozzer in Bozzer v. The Queen, 2011 FCA 186.

Counsel to Heritage Education Funds Inc. in Heritage Education Funds Inc. v. Her Majesty the Queen, 2010 TCC 161.

Counsel to a confidential client in a GST/HST Tax Court appeal settled prior to the hearing, in respect of an assessment of a financial institution's input tax credit allocation methodology.

Counsel to a confidential client in a director’s liability Tax Court appeal settled prior to the hearing, regarding an assessment for source deductions and GST/HST.

Counsel to numerous confidential clients in respect of assessments of GST/HST and income tax relating to home sales.

Counsel to numerous confidential clients in making voluntary disclosures with the CRA and Ministry of Finance.

Co-Presenter, "GST/HST – An Update and Review for the Non-Specialist," Ontario Tax Conference, October 28-29, 2024.

Presenter, “Indirect Tax Update for Non-Indirect Tax Practitioners," Canadian Tax Foundation 74th Annual Tax Conference, November 27-29, 2022.

Presenter, “Seller Beware! New Canadian Sales Tax Changes for Online Sellers,” AJAG Professional Development, June 11, 2021.

Presenter, “Duty of Care Owed to Taxpayers,” Chartered Professional Accountants Commodity Tax Symposium, October 24, 2019.

Presenter, “Case Law Update,” Chartered Professional Accountants Commodity Tax Symposium, October 16, 2018.

Presenter, "The Québec Runaway Bride: Reflections on the Canadian Indirect Tax Harmonization Process," Chartered Professional Accountants Commodity Tax Symposium, October 25, 2016.

Presenter, "Protecting Sensitive Tax Data & Nuances of Tax Litigation," The Institute of Law Clerks of Ontario, Just For Law, 26th Annual Conference, May 13, 2016.

Presenter, "Commodity Tax – Case Law Update," Tax Executives' Institute 50th Annual Canadian Tax Conference, May 3, 2016.

Presenter, "Unsuspecting Applications of the Fair Market Value Rule: Defending Challenges on Audit," Chartered Professional Accountants, September 29, 2015.

Presenter, "Directors' Liability for Unremitted Corporate Taxes: What Every Director Needs to Know," Continuing Professional Development Bootcamp, Toronto, November 12, 2014.

Presenter, "Tax and Privilege: A Primer," Continuing Professional Development Bootcamp, Toronto, November 30, 2011.

Presenter, "Case Law Update: While You Were Away This Summer," Ontario Bar Association Tax Law Section, September 21, 2011.

Presenter, "Case Law Update: A Fast and Furious Survey of Recent Decisions," Ontario Bar Association Tax Law Section, April 14, 2011.

Presenter, Canadian Tax Foundation Young Practitioners (Toronto), "HST: Key Issues of the Day," January 26, 2011.

Co-Author, "To Claim or Not to Claim – The New Age for Input Tax Credit Controversy," Tax Profile, December 2024.

Co-Author, "Canada Revenue Agency Extends Filing Deadline for Underused Housing Tax – Again," Aird & Berlis LLP, October 31, 2023.

Co-Author, "Beginning of a New Rental Construction Boom? Temporary GST Exemption for Purpose-Built Residential Rental Properties Sparks Growth Potential," Aird & Berlis LLP, September 28, 2023.

Co-Author, "Canada Country Report," Taxation of Crypto Assets, Wolters Kluwer, November 13, 2020.

Co-Author, “Duty of Care Owed to Taxpayers … And What to Do When Dealings with the CRA Go Sideways,” 2019 CPA Commodity Tax Symposium, October 2019.

Co-Author, “Callidus Capital Corporation v. Her Majesty the Queen,” Sales Tax, Customs & Trade, Federated Press, Volume XVI, No. 2, 2019.

Co-Author, “Case Law Update: 2018 CPA Commodity Tax Symposium,” 2018 CPA Commodity Tax Symposium, October 2018.

Author, “Unsuspecting Applications of Fair Market Value in the Excise Tax Act,” 2015 CPA Commodity Tax Symposium, September 2015 (Awarded the Norman Guérin Award).

Co-Author, "Case Law Update," 2012 CPA Commodity Tax Symposium, September 2012.

"Bozzer: An Interesting Victory for All Canadian Taxpayers," Tax Topics, August 2011.

"Husky Oil Limited v. The Queen: Clarifying the Scope of the Amalgamation Anti-Avoidance Rule," Tax Litigation Journal, Federated Press, Volume XVII, No. 3, 2010.

Contributor, Canadian Transfer Pricing, CCH Canadian Limited, 2nd Edition.

Co-Author, "New Litigation Process Conference Rules in Tax Court Proceedings," Tax Litigation Journal, Federated Press, Volume XVI, No. 4, 2010.

Co-Author, "Trends in Sales Tax Litigation," Report on the 2008 Canadian Tax Foundation Conference, 2009.

Co-Author, "GST and Commodity Tax Issues in Cross-Border Transactions: Expecting the Unexpected," Report on the 2007 Canadian Tax Foundation Conference, 2008.

Contributing Writer, "Federal Tax Practice," CCH Canadian Limited.

Co-Author, "Limit the Uncertainty" (regarding the scope of limitation periods in tax assessments), CA Magazine, April 2006.

Contributing Writer, "Charities, Non-Profits and Philanthropy Under the Income Tax Act," CCH Canadian Limited, 2006.

• LLM, University of California, Berkeley, School of Law, 2014
• JD (Hons.), University of Toronto, 2006
• B.A.Sc. Industrial Engineering (Hons), University of Toronto, 2003