The Law firm of TDS is advancing a group tax appeal on behalf of participants of the Global Learning Gifting Initiative (GLGI) donation program.

We represent a large group of GLGI clients in relation to their objections to the Canada Revenue Agency (CRA) reassessments denying the GLGI donation claims.

We continue to accept new clients and encourage interested individuals to contact us regarding our retainer.

Go to:
CRA Notice of Confirmation
Our Retainer
The Lawyers
Book a Consult / Contact Information
About TDS Law

Have questions? Call us: (204) 934-2340

Notice of Confirmation

CRA is beginning to issue “notices of confirmation” to GLGI participants with unresolved objections. The notice of confirmation disallows the objection and confirms the full denial of the GLGI donation claim. Recipients of notices of confirmation must appeal to the Tax Court of Canada within 90 days or else they lose the opportunity to appeal the CRA’s decision and the amounts owing become fully collectible.

Our retainer includes filing individual notices of appeal to the Tax Court for each of our GLGI clients who receive a notice of confirmation.

Recipients of notices of confirmation must appeal to the Tax Court within 90 days or else they lose the opportunity to appeal the CRA’s decision and the amounts owing become fully collectible.*

*A taxpayer who does not file the Notice of Appeal within 90 days from the date of the Notice of Confirmation can make an application to the Tax Court for an extension of time to file the Notice of Appeal but the application must be filed within one year and 90 days from the date of the Notice of Confirmation and there is no guarantee that the extension will be granted.


Our Retainer

By retaining our firm to handle your objection and appeal, you become part of our group and stand to benefit from the results achieved for the group. Our efforts have already achieved a reduction to the tax balances for GLGI clients, but we continue to press on for substantially more relief.

We have lead cases which are proceeding through the pre-trial steps in the Tax Court. The rest of our group awaits the outcome of the lead cases without having to incur the significant costs of proceeding individually. The objective is to achieve the best possible final resolution in the lead cases, through a negotiated settlement, and apply those results to the rest of the group.

The group tax appeal process offers distinct advantages to clients. As a result of the inherent synergies of appealing a common issue for the group, the cost to each individual is dramatically lowered. Moreover, a large united group creates more incentive for CRA to negotiate a settlement and avoid the costs of dealing with potentially hundreds or even thousands of individual appeals.


The Lawyers

TDS lawyer Jeff Pniowsky thumbnail image
Jeff Pniowsky

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 theProvincial and Federal courts, including the Supreme Court of Canada.

See Jeff's Full Bio


Matthew Dalloo thumbnail image
Matthew Daloo

Matthew is an associate lawyer with Thompson Dorfman Sweatman LLP. His practice is concentrated in the areas of tax litigation and dispute resolution in the tax audit, appeals, and collection processes.

See Matt’s Full Bio


Book a Consult / Contact Information

To book a consult, contact:
Colleen Millitaire
242 Hargrave Street
Winnipeg, MB, R3C 0V1
Call: (204) 934-2340


About our Firm

TDS is a full-service law firm in Winnipeg with offices across Manitoba and in Saskatchewan. We believe that collaboration is essential to providing outstanding professional service.

Working together with a shared vision, we are devoted to serving our valued clients. Our collegial workplace fosters greater teamwork, responsiveness, and communication, providing better results for clients. When we’re retained, we will refer you to the TDS lawyer with the ideal level of experience in your field, or alternatively, a legal team will be assembled to work towards a suitable solution. We aim to deliver a full-service firm that makes our team, our clients, and those who aspire to join us feel that they are free to lead.

Our History

With Manitoba roots that run more than 130 years deep, TDS has long been recognized as a leading full-service law firm dedicated to serving clients and delivering high-quality work. The firm’s team of 100 lawyers provides services in over 25 areas of practice to clients locally, nationally, and internationally across every major sector. TDS has long been recognized as a center of excellence in the areas of corporate and commercial law, labour relations, employment law, and civil litigation.

Our Accolades

The firm has been recognized by LEXPERT® on numerous occasions as being the leading corporate law firm in Manitoba. TDS has also been ranked and recommended by Chambers Global, Benchmark Litigation and recognized as one of the top regional firms in the prairies by Canadian Lawyer Magazine. In addition, several of the firm’s lawyers have been recognized by Best Lawyers® in Canada and LEXPERT® as leaders in their respective practice areas.

Community Minded

We are engaged in the communities in which we live and work. Across all of our Manitoba offices, TDS gives back and is mindful of its responsibility to make a positive contribution to our local communities. Each year TDS contributes over $250,000, supporting more than 100 worthwhile community initiatives across Manitoba that includes the arts, environment, education, the advancement of medical care, local economic development, children’s causes and providing access to legal services for disadvantaged community members. In addition, TDS lawyers contribute hundreds of hours of their time providing pro bono legal services.

A recent and notable economic development example was the firm’s decision to become the first tenant and founding partner in True North Square, playing a role in the continued revitalization of downtown Winnipeg.



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