- Bio
- Professional Involvement
- Representative Matters
- Selected Speaking Engagements
- Selected Publications
- Education
Chris is a skilled advocate with extensive experience
advising on domestic and international tax controversy and litigation matters.
He has successfully represented a wide range of clients, including
multinational corporations, financial institutions, pension funds and ultra
high net worth individuals, and he routinely acts on high value and complex
cases. Chris’ strategic approach allows him to position his clients for
effective negotiation with the tax authorities, with the objective of obtaining
favourable results efficiently and avoiding litigation when possible. He has an
exceptional track record, having successfully resolved most of his cases by
consent judgment or at the administrative appeals level.
Chris is a member of the firm’s Tax Group and Tax
Controversy/Tax Litigation Group. In addition to handling tax litigation
matters, his practice includes advising clients throughout the audit process,
remediation of tax compliance errors and making disclosures under the Voluntary
Disclosures Program, obtaining interest and penalty relief and other
discretionary remedies, and challenging collection action (and other
administrative action) taken by the tax authorities, particularly in the
cross-border context. He also collaborates with other members of the Tax Group
to assist clients with transactional and tax advisory matters.
Chris has been recognized in International Tax Review’s World
Tax Guide every year since 2019 for his expertise in Tax Controversy.
He has authored articles on a variety of tax issues in professional legal
journals and presents at conferences and other events for tax executives and
tax practitioners.
Early in his legal career, Chris completed a judicial
clerkship at the Tax Court of Canada. Prior to joining Aird & Berlis, Chris
was a senior partner at a national law firm affiliated with one of the Big 4
accounting firms, where he co-led the affiliated firm’s tax litigation practice
in Toronto.
Professional Involvement
Memberships
- Canadian Tax Foundation
- The Advocates’ Society
- American Bar Association
Representative Matters
- Tax Court appeal relating to the treatment of M&A deal costs and entitlement to claim a capital loss of approximately $1.4 billion for a Fortune 100 automotive company.
- Tax Court appeal of assessments totalling approximately $140 million in relation to a cross-border distribution for a Fortune 500 life sciences company (successfully resolved on consent).
- Tax Court appeal of an assessment in relation to the distribution of capital property held in trust and the alleged application of s. 107(4.1) of the Income Tax Act (successfully resolved on consent).
- Tax dispute regarding entitlement to GST/HST input tax credits in the context of a reverse invoicing arrangement for a global production and event management company (successfully resolved at the objection stage).
- Tax advice for a large privately-owned renewable energy company regarding the character of gains in excess of $450 million from the disposition of certain partnership interests.
- Tax dispute regarding the deductibility of losses following an acquisition of control for a pharmaceutical distribution company (successfully resolved at the audit stage).
- Represented a multinational Canadian bank in a dispute involving refunds claimed under the International Business Activity Act of British Columbia.
- Tax advice for a public multinational consumer goods company regarding whether a divestiture would be considered part of the same “series of transactions” as an earlier spin-off transaction.
- Tax Court appeal regarding the tax consequences of an intellectual property licensing arrangement for a leading industrial manufacturing company (successfully resolved on consent).
- Tax Court appeal regarding liability for minimum tax for a trust affiliated with a large construction union (successfully resolved on consent).
- Federal Court judicial review application challenging a CRA requirement to provide information and documents for a high-net-worth non-resident of Canada (resolved on consent after CRA withdrew the requirement).
- Tax dispute involving housing allowances paid to approximately 1,500 Canadian employees of a multinational consulting company (successfully resolved at the objection stage).
- Tax dispute regarding the character of periodic payments under a $200 million cross-currency interest rate swap for a major insurance company (successfully resolved at the objection stage).
Selected Speaking Engagements
Discussion Co-Leader, 2023 Cambridge Forum on International Tax & Disputes (You’ve Got a Friend – Leveraging Relationships with Treaty Partners) (May 2023, Cascais, Portugal).
Presenter, U.S. Tax Court’s Inn of Court (Resolving Tax Disputes in Canada: Overview of the Administrative Appeals Process) (March 2023).
Moot Court Judge, Donald G. H. Bowman National Tax Moot (March 2023, Toronto).
Co-panelist, 12th Annual London Finance and Capital Markets Conference (Tax Litigation panel) (January 2023, London, UK).
Moot Court Judge, Donald G. H. Bowman National Tax Moot (March 2022, Toronto).
Presenter, Deloitte Global Tax Conference – Americas (Tax Planning and Managing Tax Controversy in a Shifting Canadian Economy) (March 2021, Toronto).
Presenter, Deloitte Corporate Tax Conference (Hot Topics in Dealing with the CRA) (July 2018, Toronto).
Presenter, Deloitte Investment Management Tax Seminar (Selected Issues in Tax Controversy) (October 2017, Toronto).
Moot Court Judge, Donald G. H. Bowman National Tax Moot (March 2017, Toronto).
Co-presenter, 16th Managing Tax Audits & Investigations Course by Federated Press (Assessments, Objections and the Appeals Process) (June 2013, Toronto).
Selected Publications
Co-author, "Solicitor-Client Privilege: A Refresher," Tax Profile (Wolters Kluwer), March 2023.
Co-author, "Equitable Remedies in the Tax Context after Collins Family Trust," Tax Profile (Wolters Kluwer), August 2022.
Author, “The Federal Court of Appeal’s Decision in BP Canada Energy: New Limits on the Minister’s Power to Compel Production?” Tax Litigation (2017) Volume XX, No. 4, 2-7 (Toronto: Federated Press).
Author, “The Window may be Closing for Voluntary Disclosure of Offshore Holdings” Tax Litigation (2017) Volume XX, No. 3 (Toronto: Federated Press).
Author, “In the Headlines – Herman Grad 2000 Family Trust: Yet Another Cautionary Tale of Trust Residence” STEP Inside (2017), Volume 16, Issue No. 1 (Toronto: STEP Canada).
Co-author, “AES and Riopel: Implications for the Common Law Remedy of Rectification” Tax Litigation, (2013) Volume XIX, No. 2, 1146-1149 (Toronto: Federated Press).
Author, “Beneficial Ownership in Canada's Tax Treaties” Corporate Finance (2012) Volume XVIII, No. 3 2136-38 (Toronto: Federated Press).
Author, “Part XIII Withholding on Payments to Foreign Intermediaries” Corporate Finance, (2012) Volume XVIII, No. 1, 2082-83 (Toronto: Federated Press).
Author, “Hedging Foreign Exchange Exposure of Balance Sheet Items” Corporate Finance, (2011) Volume XVII, No.1, 1941-1943 (Toronto: Federated Press).
Author, “Trust Validity and Residency: Federal Court of Appeal Decisions in Antle and Garron” Tax Litigation, (2011) Volume XVII, No. 4, 1075-1078 (Toronto: Federated Press).
Author, “Laerstate and Corporate Residence: Ripples from Across the Pond” Corporate Finance, (2009) Volume XVI, No. 2, 1825-1828 (Toronto: Federated Press).
Education
- JD (Dean's Silver Scholar), Queen’s University, 2008
- B.Sc. in Physics (with Distinction), Western University, 2004
- Artist’s Diploma in Piano Performance (with Distinction), Western University, 2004
- CPA In-Depth Tax Course, Parts I and II