Neil Bass

Professional Involvement

Professional Activities

• Neil has authored numerous articles and conference papers on GST/HST, was a co-editor of Canadian GST and Commodity Tax Cases published by CCH Canadian Limited and is currently a contributing editor of Federated Press - Sales Tax, Customs & Trade Journal published by Thomson Reuters Canada.
• Neil addresses audiences on a variety of commodity tax matters and is a past presenter at the CICA Commodity Tax Symposium and the Canadian Tax Foundation Conference.

Memberships

• Canadian Bar Association (Commodity Tax Customs and Trade Section and Tax Court Bench & Bar Committee)
• Ontario Bar Association
• GST Leaders Forum, a group established by the LPA of the most prominent GST/HST accountants and lawyers from across Canada.

Representative Matters

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.

Represented Skyline Enterprises Management Inc. in the formation of Skyline Mortgage Investment Trust and the private placement offering of units for gross proceeds of up to $13 million.

Counsel to Costco Wholesale Canada Ltd. in Costco Wholesale Canada Ltd. v. Her Majesty the Queen, [2009] G.S.T.C 38 (Tax Court of Canada) and 2012 FCA 160 (Federal Court of Appeal).

Counsel to Jostens Canada Ltd. in Jostens Canada Ltd. v. M.N.R. and Jostens of Quebec Ltd. v. M.N.R., [1994] G.S.T.C. 34 (Canadian International Trade Tribunal).

Counsel to Corporation of City of Brantford in Brantford (City) v. The Queen, [1988] G.S.T.C. 125 (Tax Court of Canada).

Advised the City of Toronto on the GST tax appeal settlement of waste and wastewater disposal fees.

Advising Sprott Resource Lending Partnership with respect to C$72 million senior secured notes financing for North American Palladium Ltd.

Advised Premier Gold Mines Limited on the acquisition of Goldstone Resources Inc.

Selected Speaking Engagements

Speaker, "2016 Tax Year in Review," Wolters Kluwer webinar, December 14, 2016.

Guest Speaker, "2015 Commodity Tax Update," Tax Executives Institute, Commodity Tax Day 2015, January 22, 2014.

Speaker, "Here We Go Again: Revisiting Financial Services, Joint Ventures, and Nominees/Bare Trusts," CPA Commodity Tax Symposium, September 30, 2013.

Speaker, "The 2012 Case Law Update," CICA Commodity Tax Symposium, Ottawa, October 2, 2012.

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

Speaker, "Sale Tax Issues on Mergers, Acquisitions and Corporate Structuring and Takeovers," 2nd Tax Essentials for Business Transactions, Toronto, September 2011.

Selected Publications

Co-author, "Recent Amendments to the Goods and Services Tax/Harmonized Sales Tax (GST/HST)," October 2015.

Contributing author, "Tax Policy in Canada," Canadian Tax Foundation, 2012.

Co-author, "HST in Ontario," online manual, Lorman Education Services, 2011.

Co-author, "Recent Developments of Importance in Litigation - Corporate Tax," The 2010/2011 Lexpert CCCA/ACCJE Corporate Counsel Directory and Yearbook.

Author, "Recent Developments of Importance in Litigation - Corporate Tax," The 2010 Canadian Legal Lexpert Directory.

Author, "Trends in Sales Tax Litigation," Canadian Tax Foundation, 2009.

Co-author, "Managing Commodity Taxes on Imported Goods and Services," 2008 Commodity Tax Symposium.

Co-author, "GST and Commodity Tax Issues in Cross-Boarder Transactions: Expecting the Unexpected," in Report of Proceedings of the Fifty-Ninth Tax Conference, 2007 Conference Report (Toronto: Canadian Tax Foundation, 2008).

Author, "GST Voluntary Disclosures: The New Regime," 2001 Commodity Tax Symposium. 

Author, "Asset Securitization - A Sales Tax Perspective," 1998 Tax Symposium. 

Education

• LLB, Osgoode Hall Law School, 1988