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, including the Supreme Court of Canada.
His work has included challenges to complex tax avoidance techniques involving large corporate transactions, international taxation and interpretation of tax treaties. Jeff has advised 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 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
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 Honor Roll, University of Manitoba, Law
H.I. Corne Prize, highest standing Law of Contracts, University of Manitoba, Law
Solomon Greenberg moot court competition, University of Manitoba, Law
Jessup Internation Law moot court competition, second place in Canada (factum writing), University of Manitoba, Law
COMMUNITY INVOLVEMENT: Tax Committee member, Canadian Manufacturers & Exporters Manitoba
Former Chair of Norwood Nursery School
Coach for High School Boys’ Varsity and Junior Boys Soccer, Junior Girls Basketball, Junior Boys Hockey
The Supreme Court Changes the Landscape of Banking and First Nations
Outside the Supreme Court of Canada, after arguing in the appeal of the Bastien and Dube cases, I was approached by a member of the gallery and asked how important these cases were. Having only a brief moment before the fellow's taxicab shuttled him away into the bustle of downtown Ottawa, I responded in full sophisticated legalese: "pretty darn important". Read more...
Aggressive Tax Planning
Tax planning is the process of structuring one’s affairs in order to defer, reduce or even eliminate the amount of tax payable to the government. We are allowed to arrange our affairs to minimize our income taxes as long as it is done in accordance with the provisions of the Income Tax Act (ITA). The ITA contains provisions intended to limit overly aggressive tax plans and the Canada Revenue Agency (CRA) even has a separate Aggressive Tax Planning Division tasked with ferreting out those plans or business structures that they consider to be off limits. However, these limits are often difficult to discern, leaving taxpayers and their advisors wondering: how aggressive is too aggressive?. Read more...