Norton Rose Fulbright Canada LLP
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John Grant has extensive experience in tax litigation and dispute resolution. His practice involves resolving tax disputes with the Canada Revenue Agency and the provincial tax authorities, from the initial audit stage to the final resolution of litigation. He has successfully dealt with a broad range of matters of national scope, including break fees, commodity taxes, transfer pricing, donation programs, tax treaty interpretation, and corporate tax issues.
John's experience includes carriage of more than 1,500 tax litigation matters with over 100 reported decisions in matters before the Tax Court of Canada, the Federal Court, the Federal Court of Appeal, and in responses to the Supreme Court of Canada. John has also successfully resolved hundreds of matters without the need for prolonged litigation.
Before joining us, John was a highly regarded tax litigation counsel with the Department of Justice (Canada). Over the course of his career, he successfully litigated a wide array of complex income tax matters and developed significant experience in tax dispute resolution.
John is a frequent speaker at national and regional training initiatives. He has also provided training to the Canada Revenue Agency and has been a guest lecturer and instructor to young legal professionals.
John sat for two years as a presiding member of a federal administrative tribunal, issuing decisions regarding the enforcement of federal legislation.
- Ontario 2002
- Markou v Canada, 2018 TCC 66
- 1218395 Ontario Inc. v Canada, 2017 FCA 121
- Boroumend v Canada, 2016 TCC 256, confirmed on appeal, 2017 FCA 245
- French v. Canada, 2016 FCA 64
- Bonhomme v. Canada, 2016 TCC 152
- Ontario College of Teachers v. Canada, 2014 TCC 130
- Morguard Corporation v Canada, 2012 FCA 306, leave to appeal to SCC refused, 35183 (25 April 2013)
- Toastmaster Inc. v Canada, 2012 FCA 317
- General Electric Capital Canada Inc. v. Canada, 2008 TCC 668
- Rezek v Canada, 2005 FCA 227, leave to appeal to SCC refused, 31111 (15 December 2005)
- Certified Specialist (Taxation), Law Society of Ontario
- National Litigation Merit Award, Department of Justice (Canada)
- "Tax-Free Savings Accounts: Beware of the Pitfalls" (co-author), Taxes & Wealth Management, Thomson Reuters, Issue 12-1, 2019.
- Tax Litigation chapter in Miller Thomson on Estate Planning – the authoritative review of trusts, estates and taxes in Canada, (2012, loose leaf service, 2 volumes, release 2018).
- "Supreme Court of Canada Upholds Common Interest," The Canadian Bar Association BD Branch, December 2018.
- "Bakorp Management Ltd. v H.M.Q.: CRA Settlements – When Losses Are Too Remote for Consequential assessments," Taxes & Wealth Management, Thomson Reuters, Issue 11-3, 2018.
- "$1.4 million Award Against CRA for Malicious, High-handed, and Reprehensible Conduct – Samaroo v. Canada Revenue Agency," 2018 BCSC 324, Miller Thomson Tax Notes, March 9, 2018.
- "Warning for Corporate Appellants – Tax Court Invokes Ultra Vires Doctrine to Re-establish That Corporate Appellants Must Be Represented by Counsel," Taxes & Wealth Management, Thomson Reuters, Issue 11-1, 2018.
- "The New Voluntary Disclosure Program by the CRA — A narrower path but still a path!" Wolters Kluwer, national tax webinar, December 12, 2018.
- "Professionalism and Ethical Issues for Tax Lawyers" (co-chair), Ontario Bar Association, Toronto, ON, December 10, 2018.
- "Business Valuations and Dealing with CRA Challengers on Business Sales," Sale of a Business, Wolters Kluwer seminar series, Burlington, ON, October 31, 2018.
- "The New Voluntary Disclosure Program by the CRA — A narrower path but still a path!" Wolters Kluwer, national tax webinar, September 18, 2018.
- "Properly Engaging the CRA in Dispute Resolution" (moderator, co-panellist), Thomson Reuters, Toronto, ON, June 7, 2018.
- "The New Voluntary Disclosure Program by the CRA — A narrower path but still a path!" Wolters Kluwer, national tax webinar, June 5, 2018.
- Lecturer, Guelph-Humber Institute of Technology, Paralegal Program, 2004-2011.
- Canadian Bar Association
- Law Society of Ontario
- Ontario Bar Association
- The Advocates' Society
- Canadian Tax Foundation
- OBA Executive, Public Affairs Liaison - Taxation Law Section, 2019 - 2010
- Committee member, Department of Justice Canada, Tax Law Services Division, Student Recruitment Committee, 2007 - 2008, 2010 — 2017
- Committee member, Department of Justice Canada, Tax Law Services Division, National Tax Law Services Projects Coordination Group, 2017
- Coordinator, Department of Justice Canada, Tax Court of Canada - Pro Bono Amicus Program, 2013 - 2016