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Wilfrid Lefebvre, QC

Senior Partner

Wilfrid Lefebvre, QC

Montréal

T:+1 514.847.4440

Wilfrid Lefebvre practises in the areas of income tax and represents clients before tax authorities and courts. 

He has extensive court experience and has served as legal counsel in many complex and important cases. He has appeared on numerous occasions before the Supreme Court and the Federal Court of Appeal. He was appointed Queen's Counsel in 1982.

Mr. Lefebvre started his career at the Department of Justice in Ottawa, where he worked as a legal advisor to the Department of Supply and Services, subsequently joining the Tax Litigation Section of the Department of Justice. In 1976, he became the director of the Legal Services Branch of Revenue Canada and in 1978 was appointed general counsel in charge of tax litigation in Canada. He was a member of the Technical Committee on Business Taxation (Mintz Committee) appointed by the Canadian minister of finance to review and recommend changes to the Canadian tax regime, which tabled its report in 1997.

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  • Education

    LL.L., Université de Montréal, 1969
    B.A., Collège Saint-Laurent, 1966

  • Representative experience

     

    Mr. Lefebvre is known as an expert mediator. He has thus resolved, without the necessity of litigation, the vast majority of the cases he has handled. He is currently handling many transfer pricing cases involving public companies in the pharmaceutical, construction, apparel, industrial and services sectors. He is also responsible for many cases in which international and treaty issues are raised.

    Clients for whom Mr. Lefebvre acted include the following:

    • Valiant Cleaning Technology Inc., as lead counsel before the Tax Court of Canada in a case involving the determination of whether advances made by the taxpayer to its UK-based subsidiary were on income account, and not capital
    • Bombardier Inc., as lead counsel before the Quebec courts in a case involving capital tax issues of substantial monetary importance
    • Hydro-Québec, as lead counsel in a case of national importance involving the determination of whether the entire network equipment of Hydro-Québec was exempt from federal sales tax. In the final analysis, more than $250 million was refunded to the client
    • CAE Inc., as lead counsel before the Federal Court of Appeal on the question of the tax treatment of the sale of simulators
    • Mr. Lefebvre was appointed amicus curiae to the Supreme Court of Canada to debate the constitutional validity of provincial sales tax legislation

     

  • Admissions
    • Quebec 1970
  • Rankings and recognitions
    • Chambers Global, Canada: Tax - Litigation (Senior Statesperson), Chambers and Partners, 2018
    • Chambers Canada, Nationwide: Tax - Litigation (Senior Statesperson), Chambers and Partners, 2019
    • Best Lawyers in Canada, 2006-2017: Tax Law
    • The Legal 500 Canada, 2018: Tax (Leading Lawyer)
    • Canadian Legal Lexpert Directory, 2012-2017: recommended in Estate & Personal Tax Planning – Estate Litigation; Litigation – Corporate Tax
    • Who’s Who Legal, Canada 2015: Canada - Corporate Tax
    • Lexpert®/American Lawyer Guide to the Leading 500 Lawyers in Canada, 2012–2013: most frequently recommended in the area of Corporate Tax Litigation
    • Lexpert® Guide to the Leading US/Canada Cross-border Litigation Lawyers in Canada (US Litigation Guide), 2011: Litigation – Corporate tax
    • PLC Which Lawyer? 2011: Tax; Tax litigation
    • Best Lawyers in Canada – Lawyer of the Year 2010: Tax Law, Montréal
  • Speaking engagements
    • Frequent speaker at conferences sponsored by the Canadian Tax Foundation and the Tax Executives Institute
  • Memberships and activities

     

    • Canadian Tax Foundation
      • past member, Board of Governors
      • former Chair, Executive Committee
      • past Chair
    • Association de planification fiscale et financière (fiscal and financial planning association)
      • former president
    • Former lecturer, Faculty of Law, University of Ottawa (both civil law and common law programs), University of Sherbrooke, Law Society of Upper Canada and Quebec Bar Admission Course