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Christopher Slade

Partner Admitted to the Ontario Bar: 2009

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 at the administrative level or by consent judgment.

Chris is a member of the firm’s Tax Group and Tax Controversy/Tax Litigation Group. In addition to resolving tax disputes, his practice includes navigating the audit process (including audits under the Canada Revenue Agency’s Related Party Initiative), disclosures under the Voluntary Disclosures Program, requesting interest and penalty relief and other discretionary remedies, challenging collection action initiated by the tax authorities, and applications for rectification of transactions that resulted in unintended tax consequences. 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 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

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 totaling approximately $140 million in relation to a cross-border distribution for a Fortune 500 life sciences company.
  • 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

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

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