Deloitte Legal Canada LLP
Chris is a partner in the Toronto office of Deloitte Legal Canada LLP. His practice is primarily focused on tax litigation and tax controversy, but also includes corporate tax and international tax advisory engagements. He was admitted to the Law Society of Upper Canada in 2009 after receiving his Juris Doctor from Queen's University and completing a clerkship at the Tax Court of Canada.
Chris has successfully represented clients in a wide variety of domestic and international tax disputes involving the Canada Revenue Agency and the provincial tax authorities, and in litigation proceedings in the Tax Court of Canada, the Ontario Superior Court of Justice and the Federal Court of Appeal. Representative recent engagements include the following:
- successful resolution of a $450 million transfer pricing dispute for a Fortune 100 company, which involved an application for judicial review in the Federal Court to challenge a decision of the Canada Revenue Agency to deny a request for "downward adjustments";
- successful resolution of an income and withholding tax issue involving housing allowances paid to approximately 1,500 employees of a multinational consulting company;
- successful challenge of a Canada Revenue Agency decision to deny interest relief for a large U.S. commercial bank;
- successful resolution of a tax dispute for a major insurance company in respect of the taxation of periodic payments under a $200 million cross-currency interest rate swap;
- successful challenge of a requirement to provide foreign-based information and documents issued to a Fortune 500 company in the entertainment industry;
- currently a member of the tax controversy team representing a Fortune 100 company regarding transfer pricing assessments in relation to the disposition of intellectual property operations valued at approximately $5 billion; and
- currently representing a Fortune 500 company in the life sciences industry regarding non-resident withholding tax assessments totalling approximately $100 million in relation to a cross-border distribution.
Chris also has significant experience with applications for rectification of transactions that have unintended tax consequences, challenging collection action initiated by the tax authorities and assisting clients with proposals to provide security in lieu of payment, resolving complex estate and personal tax disputes for high net-worth individuals, and with disclosures under the Canada Revenue Agency's Voluntary Disclosures Program.
Prior to joining Deloitte Legal Canada LLP in 2013, Chris worked as a tax associate at another national law firm where his practice covered all areas of corporate income tax law.
Memberships and Professional Affiliations:
- Canadian Tax Foundation
- The Advocates' Society
- Queen's University: J.D. (2008, Dean's Silver Scholar)
- University of Western Ontario: B. Sc. Physics (2004, with distinction), Art. Dip. Piano Perf. (2004, with distinction)
- CPA In-Depth Tax Course, Parts I and II