Leading Cinema Operator
Acted for a leading cinema operator in its successful tax dispute with the Canada Revenue Agency in connection with the treatment of the sale of a movie theatre as a capital versus income gain.
Partner
Partner
Jacob combines his technical tax expertise and strategic thinking to help his clients navigate complex tax disputes.
He has argued before the Tax Court of Canada and the Federal Court of Appeal on matters ranging from income tax, excise tax, and the general anti-avoidance rule (GAAR), and has successfully resolved numerous cases before trial. He has argued before the Federal Court of Canada on judicial review applications and the Ontario Superior Court (Commercial List) on orders for rectification and commercial disputes, and regularly advises clients with respect to voluntary disclosures, tax compliance and audits, and objections and appeals. He further advises both domestic and international clients on corporate tax, tax planning, M&A, business structuring, and reorganizations.
Jacob is an active publisher and speaker and is an editor of Federated Press’ International Tax Planning.
Partner
Jacob combines his technical tax expertise and strategic thinking to help his clients navigate complex tax disputes.
He has argued before the Tax Court of Canada and the Federal Court of Appeal on matters ranging from income tax, excise tax, and the general anti-avoidance rule (GAAR), and has successfully resolved numerous cases before trial. He has argued before the Federal Court of Canada on judicial review applications and the Ontario Superior Court (Commercial List) on orders for rectification and commercial disputes, and regularly advises clients with respect to voluntary disclosures, tax compliance and audits, and objections and appeals. He further advises both domestic and international clients on corporate tax, tax planning, M&A, business structuring, and reorganizations.
Jacob is an active publisher and speaker and is an editor of Federated Press’ International Tax Planning.
Leading Cinema Operator
Acted for a leading cinema operator in its successful tax dispute with the Canada Revenue Agency in connection with the treatment of the sale of a movie theatre as a capital versus income gain.
The Proposed Enhancement of CRA’s Audit Powers, Part Two: Unpacking the New Non-Compliance Regime
May 24, 2024 - The following article was originally published in Law360 Canada. In part one of this series, we discussed how Budget 2024 marks a significant turning point for the Canada Revenue Agency (CRA), introducing measures that substantially bolster its audit powers. In this part, we discuss the...
Interview, Canadian Lawyer Magazine, “New CRA audit powers proposed in federal budget raise uncertainty, say Davies tax lawyers”; Web Publication
May 22, 2024 - Read the article.
The Proposed Enhancement of the CRA’s Audit Powers, Part One: Under Penalty of Perjury
May 03, 2024 - The following article was originally published in Law360 Canada. Budget 2024 proposes to substantially bolster the Canada Revenue Agency’s (CRA) audit powers, underscoring the increasing burden on taxpayers to comply with information requests and the consequences of non-compliance. The...
Federal Budget 2024: How It Impacts You and Your Business
Apr. 16, 2024 - The Honourable Chrystia Freeland, Deputy Prime Minister of Canada and Minister of Finance, delivered the Liberal Party’s federal budget (Budget 2024) on April 16, 2024. Budget 2024 included a number of proposed changes to the Income Tax Act (ITA) and other tax legislation. The most...
Down but not out: Rectification granted by the Ontario Superior Court to correct trust deeds, co-author
Nov. 27, 2023 - Mondaq
Read the article.
Canadian Tax Foundation, Celebrating the Tax Court of Canada, “40th Anniversary of the Tax Court of Canada Conference”; Toronto, ON
Oct. 05, 2023
Canada Revenue Agency’s expanded audit powers: What taxpayers need to know, part two, co-author
Oct. 02, 2023 - Law360 Canada
Read the article.
Canada Revenue Agency’s expanded audit powers: What taxpayers need to know, part one, co-author
Aug. 14, 2023 - Law360 Canada
Read the article.
Emergis v. The King: Taxpayer Emerges Victorious in Tower Structure Deduction
Jan. 02, 2023 - International Tax Planning, Volume XXVII, No. 2
Canadian Tax Foundation , “Case Law Update”, Canadian Tax Foundation Young Practitioners Series; Toronto, ON
Mar. 31, 2022
Loblaw Financial Holdings—Statutory Interpretation in 'One of the Most Complicated Statutory Regimes in Canadian Law’
Jan. 03, 2022 - International Tax Planning, Volume XXVI No. 2
Federal Budget 2022: What you and your clients need to know
Jan. 03, 2022 - The Lawyer’s Daily
Canadian Tax Foundation, “What’s New With Section 160?”, 2021 Ontario Tax Conference; Toronto, ON
Oct. 26, 2021
Coca-Cola Goes Flat in $9 Billion Transfer-Pricing Loss
Jan. 01, 2021 - International Tax Planning, Volume XXV No. 1
How Specific Is a ‘Specific Expense’ Under Paragraph 212(4)(B)?
Jan. 01, 2020 - International Tax Planning, Volume XXIV No. 1
Bank of Montreal v. The Queen: When a Disposition of Shares Isn’t a Disposition of Shares
Jan. 01, 2020 - International Tax Planning, Volume XXIV No. 2
Ontario, 2016
Osgoode Hall Law School, JD, 2015
Queen’s University, BSc (Applied Science, Electrical Engineering), 2007
The Advocates’ Society
Canadian Tax Foundation
International Fiscal Association
Federation of Asian Canadian Lawyers
The Advocates’ Society, Practice Group Leader - Tax Litigation Practice Group
155 Wellington Street West
Toronto, ON, M5V 3J7
Reception: 40th Floor
416.863.0900
1501 McGill College Avenue
Montréal, QC, H3A 3N9
Reception: 27th Floor
514.841.6400
900 Third Avenue
New York, NY 10022
Reception: 24th Floor
212.588.5500
For media-related inquiries, contact Stéphanie Rioton at 416.367.7917 or Suzanne Donnels at 416.367.6978.
For general inquiries, contact info@dwpv.com.