Dominic C. Belley

Norton Rose Fulbright Canada LLP

Dominic C. Belley

Dominic C. Belley


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Dominic Belley is a tax litigator. He is co-chair of Norton Rose Fulbright's Canadian tax team. He is also chairman of the firm’s pension plan.

Dominic is one of only five Canadians to be ranked as a leading tax litigator by all three major international guides to the legal profession: Chambers, Legal 500 and Lexpert / American Lawyer Guide to the Leading 500 Lawyers in Canada.

In 20 years of practice, Dominic has argued over 200 cases on behalf of taxpayers in seven out of 10 Canadian provinces. He has represented taxpayers against federal, provincial and municipal tax authorities in civil, commercial, criminal and constitutional matters before the Court of Québec, the Québec Superior Court, the Québec Court of Appeal, the B.C. Supreme Court, the Alberta Court of King’s Bench, the Ontario Superior Court of Justice, the Nova Scotia Supreme Court, the Tax Court of Canada, the Federal Court and the Federal Court of Appeal.

Dominic has argued five cases before the Supreme Court of Canada as lead counsel for the appellant, the respondent and the intervener.

His domestic tax experience includes the general anti-avoidance rule (GAAR), tax on capital, the goods and services tax (GST), interest deductibility, hybrid transactions, the capital gains exemption, capital cost allowance, debt forgiveness, taxation of partnerships, trusts and estates, scientific research and experimental development (SR&ED), real estate, stock options, protection of tax information and cancellation of penalties.

His international tax experience includes transfer pricing, foreign accrual property income (FAPI), residency, corporate migrations, the thin capitalization rules, de facto control by non-residents, international and inter-provincial allocation of income, anti-discrimination treaty provisions, and access to and protection of tax information through tax conventions.

His experience in Aboriginal taxation includes negotiating an agreement with an Indian band on the application and administration of on-reserve taxes levied against non-Aboriginal taxpayers.

Dominic is recognized nationwide for his in-depth knowledge of the law of rectification. He has successfully handled over 40 rectification cases in common law, civil law and corporate law.

Dominic has taught taxation for many years at the Quebec Bar School, the University of Sherbrooke and HEC Montreal. He has published and given speeches in Canada, the United States, the United Kingdom, France, as well as the United Nations in Geneva, Switzerland.

Dominic is a former member of the board of the Canadian Tax Foundation and of the Bench and Bar Committees of the Tax Court of Canada and the Court of Quebec.

He is a current member of the Rules Committee and the Judicial Advisory Committee of the Tax Court of Canada.

Professional experience

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In-depth Tax Course, C.I.C.A., 2005
Tax Law for Lawyers, Canadian Bar Association, 2002
B.C.L./LL.B., McGill University, 2000


  • British Columbia 2021
  • Quebec 2001

Selected cases argued by Dominic Belley:

  • Des Groseillers v. Québec, 2022 SCC 42. 
  • Barreau du Québec v. Québec, 2017 SCC 56. 
  • Jean Coutu inc. v. Canada, 2016 SCC 55. 
  • Guindon v. Canada, 2015 SCC 41. 
  • Québec c. Services environnementaux AES Inc., 2013 SCC 65. 
  • BP Canada Energy Company. v. Canada, 2017 FCA 61. 
  • CAE Inc. v. Canada, 2013 FCA 92. 
  • Canada v. Bombardier, 2012 FCA 46.
  • Valiant Cleaning Technology Inc. v. Canada, 2008 TCC 637
  • Lafarge Canada Inc. v. Québec, 2011 QCCS 7391
  • Best Lawyers in Canada: Tax Law, 2018-2024 
  • Chambers Global, Canada: Tax: Litigation, Chambers and Partners, 2020-2024
  • The Legal 500 Canada: Tax (Leading Individuals), 2023-2024 
  • Lexpert/American Lawyer Guide to the Leading 500 Lawyers in Canada: Litigation - Corporate Tax, 2024
  • Canadian Legal Lexpert Directory, 2017-2024: recommended in Litigation - Corporate Tax 
  • Chambers Canada, Nationwide: Tax: Litigation, Chambers and Partners, 2018-2023
  • University of Sherbrooke – Dean’s Honour List – Excellence in Teaching, 2011, 2012, 2013
  • Young Bar Association of Montreal (AJBM) - 2009 Lawyer of the Year (Civil and Commercial Litigation)
  • Prize awarded by the Fondation du Barreau, 2000
  • Prize awarded by the Canadian Tax Foundation, 1999
  • "Tax Certainty," 2019 Annual Tax Conference, Montreal, Canadian Tax Foundation, 2019.
  • "Canada," The Tax Disputes and Litigation Review, 7th Ed., London, Law Business Research, 2019.
  • "Canada" (with J. Lafrance), The Transfer Pricing Law Review, 2nd Ed., London, Law Business Research, 2018.
  • "Judicial Review," Federal Court Practice Conference, Montreal, Canadian Tax Foundation, 2018.
  • "International Tax Transparency" (with M. Lennard), Geneva, TAXCOOP, 2017.
  • "GAAR, SAARs and the Sham Doctrine," 2017 Annual Tax Conference, Toronto, Canadian Tax Foundation, 2017.
  • "Les Rapports juridiques véritables," Congrès 2017, Montreal, Association de planification fiscale et successorale, 2017.
  • "Procedure and Evidence in Tax Appeals," 2015 Annual Conference, Montreal, Canadian Tax Foundation, 2015.
  • "The Correction of Mistakes in Quebec Corporate Law," Corporate Liability, Vol. 16, No. 3, 2011.
  • "Indian Taxation Powers: Sharing Canadian Prosperity," Revue du Barreau 185, 2000.
  • Canadian Bar Association
  • Canadian Tax Foundation
  • International Fiscal Association
  • Lecturer, Taxation, Quebec Bar Admission Course
  • Lecturer, Tax Litigation, University of Sherbrooke
  • Association de planification fiscale et financière (tax and financial planning association) – liaison committee with tax authorities
  • Sclérodermie Québec (2007-2014)


  • English
  • French


2023 Canadian Federal Budget

Publication | March 29, 2023

2022 Canadian Federal Budget: Administration and disputes

Publication | April 20, 2022