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Jeffrey D. Pniowsky

Jeff focuses his practice in the areas of tax litigation and dispute resolution in the tax audit and appeals process, tax advisory services, as well as complex commercial litigation. Formerly a senior Tax Litigator with the Federal Department of Justice acting on behalf of the Canada Revenue Agency (CRA) for almost 10 years, Jeff now serves local and national clients with a wealth of experience in litigating at all levels of both the Provincial and Federal courts.

His work has included challenges to complex tax avoidance techniques involving large corporate transactions, international taxation and interpretation of tax treaties. Most recently, Jeff had been advising the Aggressive Tax Planning Division of CRA involving some of the most significant tax matters in the Prairie region. He also sat on the National Tax Avoidance Committee for Justice Canada.

In addition, Jeff has extensive experience dealing with tax enforcement and other regulatory compliance issues including document disclosure requirements and was a member of National Documentary Requirements Committee. He is also considered an authority on solicitor and client privilege issues relating to documentary disclosure, having litigated several matters in this area as well as being called upon to act as an adjudicator in a privilege determination.

Education

LLB, University of Manitoba, 1994

MBA, Case Western Reserve University, Cleveland, Ohio, 1999

Call to the Bar

June 1995

Representative Cases
On May 20, 2010, appeared at the Supreme Court of Canada on behalf of the intervener Assembly of Manitoba Chiefs in the cases of Bastien v. The Queen and Dube v. The Queen regarding the exemption from taxation of banking interest income earned on an Indian reserve.

Currently representing over 100 investors before the Tax Court of Canada appealing a determination of ineligibility as a qualified investment under an RRSP.  The appeal is part of a national CRA project audit dealing with RRSPs.

Acting on behalf of a trust in an appeal to the Tax Court of Canada challenging the CRA’s use of the General Anti-Avoidance Rule (GAAR) to apply dividend income to the trust with respect to a corporate reorganization.

Representing a research organization in an appeal before the Tax Court of Canada of the CRA’s denial of scientific research and experimental development (SR&ED) tax credits for Canadian based research of internationally sponsored medical trials.

Eaton v. Canada, 2008 FCA 162 (Federal Court of Appeal) -  appeal from the Tax Court of Canada regarding tax treatment of a national compensation award to Federal civil servants by the Canadian Human Rights Tribunal.

Bourgault Industries Ltd. v. Canada, 2007 FCA 373 (Federal Court of Appeal) - appeal from the Tax Court of Canada regarding the tax status of settlements arising out of intellectual property disputes.

Canada v. Moss, 2001 MBCA 166 (Manitoba Court of Appeal) - appeal from the Manitoba Court of Queen’s Bench allowing the first annulment of a bankruptcy by a Manitoba court.

Achievements

Prairie Region Award of Excellence, Department of Justice, 2007
Weatherhead Scholarship, Case Western Reserve University School of Management
Strategic Management Comprehensive Case Competition, first place, Case Western Reserve University School of Management
Dean’s Honour Roll, University of Manitoba, Law
H. I. Corne Prize, highest standing in Law of Contracts, University of Manitoba, Law
Solomon Greenberg moot court competition, finalist, University of Manitoba, Law
Jessup International Law moot court competition, second place in Canada (factum writing), University of Manitoba, Law

Professional Associations

Member of the Canadian Bar Association, the Manitoba Bar Association and the Law Society of Manitoba
Member of Lex Mundi
Member of the Canadian Tax Foundation

Community Involvement and Other Affiliations

Tax Committee Member, Canadian Manufacturers & Exporters Manitoba
Former Chair of Norwood Nursery School
Coach for High School Boy’s Varsity and Junior Boys Soccer, Junior Girls Basketball, Junior Boys Hockey