Jeff focuses his practice in the areas of tax litigation and dispute resolution in the tax audit and appeals process, tax advisory services, and complex commercial litigation.
Jeff is a partner with TDS who 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.
LLB, University of Manitoba, 1994
MBA, Case Western Reserve University, Cleveland, Ohio, 1999
June, 1995
Recognized in the 2024 Canadian Legal Lexpert® Directory in Litigation – Corporate Tax
Named in the 2013 – 2022 Best Lawyers in Canada directory in the area of Tax Law
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 International Law moot court competition, second place in Canada (factum writing), University of Manitoba, Law
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
TDS Law was pleased to be a gold sponsor of Centrallia for another year. As part of our commitment to this conference we hosted a seminar, Doing Business in Canada,… Learn More
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… Learn More
How Aggressive Is Too Aggressive? The leaves are falling, the air is turning cool, the kids are going back to school and our summer holidays are quickly becoming mere… Learn More
Personal Tax Liability Looms The recent decision of the Tax Court in Williamson v. The Queen is a good reminder of the personal obligations directors have under the Income Tax… Learn More
It is finally spring. The snow has melted, the flowers bloom, children put down their video games and leave their winter dens behind to frolic in the sunshine. What better… Learn More
Reduce the Risk of an Adverse Audit If you are buying a property in the U.S. with the intention of renting it out, you should be aware of the potential… Learn More
Thompson Dorfman Sweatman LLP Partner Jeff Pniowsky has successfully argued a landmark case before The Tax Court of Canada with the court issuing a scathing 52-page decision. The decision allows… Learn More
In early 2016, Jeff Pniowsky of Thompson Dorfman Sweatman LLP was approached to represent a large oil services company in Alberta, along with its principal officers, in connection with several… Learn More
Ritchie v. The Queen, 2018 TCC 113, was a lead case for hundreds of farmers across the Canadian Prairies. Jeff Pniowsky of Thompson Dorfman Sweatman LLP successfully argued that the… Learn More
Jeff 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… Learn More
Recently, the expanding TDS Law Tax Litigation Practice successfully represented clients against the Canada Revenue Agency (CRA) on the following matter: In the case of St. Arnaud et al. v.… Learn More