Natalie Goulard

Partner

Montréal
[email protected]
514.954.2556

Natalie specializes in all aspects of litigation and tax dispute resolution. She provides strategic counsel and assists clients with their tax-related controversies at the federal and provincial levels.

Natalie has extensive trial and appellate experience litigating complex and high-stakes tax matters involving issues such as treaty interpretation, tax avoidance, the general anti-avoidance rule, corporate reorganizations and transfer pricing. She is also experienced in dealing with administrative and procedural issues.

Prior to joining BLG, Natalie was a Senior General Counsel at the Department of Justice, where she gained invaluable experience working for more than 20 years as a tax litigator before all levels of court. Natalie is a frequent speaker at seminars related to taxation and the art of advocacy.

Experience

  • R. v. Alta Energy Luxembourg S.A.R.L., 2021 SCC 49, 2020 FCA 43 – Counsel on a Supreme Court of Canada appeal involving the application of the general anti-avoidance rule to tax treaty provisions exempting a capital gain in excess of $380 million from tax in Canada.
  • Canadian Imperial Bank of Commerce v. R., 2021 TCC 71 – Lead counsel on a case involving the interpretation of specific anti-avoidance rules and their application to a deemed capital loss of $124,400,000.
  • R. v. Damis Properties Inc., 2021 TCC 44 – Lead counsel in a dispute concerning the income tax consequences under section 160 of the Income Tax Act and the general-anti-avoidance rule of a series of transactions undertaken to increase the after-tax return of an investment in farmland.
  • The Gladwin Realty Corporation v. R., 2020 FCA 142, 2019 TCC 62 – Lead trial and appellate counsel on a case involving the application of the general anti-avoidance rule to a series of transactions undertaken to minimize the amount of tax payable in connection with the sale of a commercial real estate property.
  • R. v. Bank of Montreal, 2020 FCA 82, 2021 TCC 3 – Lead trial and appellate counsel on a case involving the general anti-avoidance rule and its application to the loss of $321,755,972 BMO sustained on a deemed disposition of shares.
  • Patel v. R., 2020 FCA 27 – Lead appellate counsel on a procedural case involving the bifurcation of issues in the parties’ appeals.
  • 4092325 Investments Ltd. v. R., 2019 FCA 225, 2018 TCC 228 – Lead trial and appellate counsel on a procedural case involving the lead case rules and a large group of files.
  • Negus v. Canada, 2019 FCA 159 – Lead appellate counsel on a case involving procedural issues and litigation management in a large group of files.

Beyond Our Walls

Professional Involvement

  • Member, The Advocates’ Society
  • Member, The Canadian Tax Foundation (CTF)
  • Member, L’Association de planification fiscale et financière (APFF)

Bar Admission & Education

  • Québec, 2018
  • Ontario, 1995
  • LLB, University of Ottawa, 1993
  • BA Psychology, University of Ottawa, 1990