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Laurie assists clients with tax litigation and dispute resolution, from the audit and objection stages to appeals before the courts.
Her practice involves:
resolving and litigating, if necessary, tax issues such as the GAAR and tax avoidance, computation of profit, the meaning of inventory, interest deductibility, transfer pricing, deductibility of certain benefits, treaty interpretation, and corporate reorganizations
assisting with complex tax audits
ensuring that tax authorities operate within lawful parameters regarding their demands for information and documentation
correcting non-compliance issues
representing corporate taxpayers in sales tax, fuel tax and other commodity tax disputes
pursuing judicial reviews in connection with the actions of taxing authorities
obtaining rectification and related equitable remedies related to transactions with unintended tax consequences
assisting clients participating in the Canada Revenue Agency (CRA) Voluntary Disclosure Program
Laurie regularly appears before all levels of courts in Alberta and has appeared before the Tax Court of Canada, the Federal Court of Canada and the Supreme Court of Canada.
Laurie has completed the Chartered Professional Accountants Canada in-depth tax course.
Within our firm, Laurie is currently Regional Group Manager of Specialized Business Law and National Leader of our Tax Disputes and Litigation Group.
Laurie fournit des services juridiques par l’intermédiaire d’une société professionnelle.
R v Yang, 2020 CarswellAlta 2621 (ABQB), represented individual target and related closely-held corporations in multiple court appearances as related to 15 simultaneous search warrants executed cross-country in the first publicized “Panama Papers" tax evasion investigation in Canada.
Deans Knight Income Corp. v. Canada, 2023 SCC 16 - acted as counsel for the Canadian Chamber of Commerce intervening before the Supreme Court of Canada in this seminal case addressing the application of the general anti-avoidance rule (GAAR) under the Income Tax Act (Canada).
John Wood Group PLC in the US$67 million sale of its joint venture interest in TransCanada Turbines to joint venture partner TC Energy.
Kerry (Canada) Inc. v. Canada, 2019 FC 377: Successful application for judicial review to give effect to a decision of Canadian Competent Authority in the context of a transfer pricing dispute.
Burlington Resources Ltd. v. British Columbia, 2013 BCSC 292; 2015 BCCA 19: Lead counsel to a number of well servicing contractors in a long-standing, industry-wide dispute involving the applicability of provincial sales tax.
Neville v. National Foundation for Christian Leadership, 2014 BCCA 38: Appellate counsel to taxpayers in connection with the treatment of gifts under common law.
R v.Husky Oil Operations Limited, 2014 SKQB 116: Lead trial counsel in a successful multi-week trial to a number of well servicing contractors in a long-standing industry-wide dispute involving the applicability of provincial sales tax.
Transalta Corporation v. Canada, 2012 FCA 20: Appellate counsel to a major power company in its successful appeal in relation to a taxpayer’s right to allocate sale proceeds between asset classes on the sale of a business.
Canada v.Remai, 2009 FCA 340: Appellate counsel to an estate in a successful appeal from reassessment by the CRA which disallowed charitable tax credits in respect of donation of two promissory notes to a charitable foundation and related GAAR claims.
R v.Breakell, 2009 ABCA 350: Appellate counsel to an individual charged under the tax evasion provisions of the Canadian Income Tax Act.
Canada v.Addison & Leyen Ltd.,2007 SCC 33: Appellate counsel in connection with a precedent-setting case regarding the ability to seek relief for unfair treatment by the CRA under section 160 of the Income Tax Act.
AltaGas Marketing Inc. et alv. Her Majesty the Queen, 2007 FC 1234: Trial and appellate counsel to a number of petroleum producers in Alberta and Inuvik in the successful interpretation of a production license issued under the Canada Petroleum Resources Act and the assessment of royalty taxes payable to the Crown under it.
IFP Technologies (Canada)v. Encana Midstream and Marketing, 2014 ABQB 470: Trial counsel in a lengthy trial to a major Canadian resource company in the successful defence to a multi-million-dollar contractual claim involving a SAGD prospect.