Tax Litigation
Negotiating Experience and Expertise
Nowhere is negotiation and settlement more important than in the context of taxation disputes. Over his decades of experience, first as a commercial litigation partner at a leading Toronto law firm, and then as a sole practitioner, Patrick has developed a reputation as a civil, fair and effective negotiator. Patrick is known to overlook no opportunity to reach a settlement in his client’s best interests, thus avoiding costly and time consuming court proceedings. Patrick’s reputation provides credibility with tax counsel in the Department of Justice facilitating settlement of difficult tax cases.
Seasoned Advocacy
Where differences are irreconcilable and court proceedings are necessary, it is important that the tax litigator have the ability to cope with the complexities which abound in tax law and to present the client’s case articulately and effectively . It is recognized that experienced commercial litigators are more effective advocates in tax cases than tax advisors are. The Tax Court of Canada has commented on Patrick’s ability to "ably set out" his client’s case.
Click Here to Read the Summary of a Tax Case Handled by Patrick
Academic and Intellectual Depth
Patrick’s recent completion of a Master of Laws in Taxation at York University’s Osgoode Hall has sharpened his awareness of the approaches taken by all levels of the Courts in Canada in adjudicating tax disputes. This enables him to make an up-to-date legal assessment of prospective clients’ cases, and weigh the strategic interests of taxation authorities in the dispute.
Some of Patrick's recent papers on tax law and policy (click on title to view full text in pdf):
Financial Instruments and the Canadian Income Tax Act
The Implications of the Mark Resources Case for the Taxation of Corporations and Their Shareholders
Policy Considerations at Play in the Taxation of Foreign Source Income
Is it Time to Abolish Criminal Prosecution for Tax Offences?
_________________________