Vern Krishna

E-Card

Vern Krishna
Exec. Dir. CGA Tax Rsrch Centre and Full Professor

C.M.
Q.C.
MBA
LL.M (Harvard)
Dip. Law (Cantab) MCIArb
FCGA

Room: 57, Louis Pasteur St., Room 114
Office: 613-562-5800 ext. 5203
Office: 613-562-5124
Work E-mail: Vern.Krishna@uOttawa.ca

Vern Krishna

Biography

Professor Krishna joined Faculty of Common Law in 1981 and teaches taxation, business law and corporate finance. Krishna is a graduate (B.Com.) of the University of Manchester (UK) in economics and business; he holds an M.B.A. and LL.B. from the University of Alberta; and he obtained an LL.M. from Harvard University and a Diploma in Comparative Law from Cambridge University in the United Kingdom. He is a member of the Ontario Bar and is Of Counsel, Borden Ladner Gervais LLP.

Krishna is a member of the Order of Canada (2004).  He was appointed Queen’s Counsel (1989) by the Government of Canada, elected a Fellow of the Royal Society of Canada (1992), and a Fellow of the Certified General Accountants of Canada (1989). He received a LL.D. from the Law Society of Upper Canada in 2004 and the 125th Canada Medal (1993) from the Governor General of Canada.

Krishna has been active in both of his professions – law and accounting. He has been a Bencher of the Law Society of Upper Canada since 1990 and served as its elected head [Treasurer] from 2001 to 2003. He was elected President of the Certified General Accountants Association of Ontario in 1995.

Krishna is the author of twelve texts in tax, international tax, and business law (see sidebar "Books") and numerous articles and case comments. His writings are frequently cited by the Supreme Court of Canada (see below). He served as a Commissioner on the Ontario Securities Commission from 1995 to 1998 and was a Visiting Scholar in International Tax at Harvard Law School from 1998 to 1999. 

Professor Krishna is a Member of the Chartered Institute of Arbitrators.

Lexpert’s Directory of Best Lawyers in Canada lists Professor Krishna in the areas of:

IncomeTax, and Trusts & Estates.

Professor Krishna is mentioned in Who’s Who Canada


Professional Activities

  • Treasurer (President) of the Law Society of Upper Canada  2001 - 03
  • President, Certified General Accountants Association (Ontario)  1995 - 96
  • Member of Minister of Revenue’s Appeals Advisory Committee 1997 - 99
  • Managing Editor, Canadian Corporate Law Reporter,   
    LexisNexis, Toronto.
  • Managing Editor, Canadian Current Tax,      
    LexisNexis, Toronto.
  • Managing Editor, Canada’s Tax Treaties,     
    LexisNexis, Toronto
  • Managing Editor, Ontario Law Reports,
    LexisNexis, Toronto
  • Director of Public Accountants Council of Ontario 2005 –

Professional Honours

  • Indo-Canadian Chamber of Commerce
    Professional Man of the Year     2002
  • CGA Ontario Ivy Thomas Award    2005
     (for public and community service)
  • CGA Canada John Leslie Award    2006
  • Citations by Supreme Court of Canada

[As at December 31, 2008]

  • Schwartz v. Canada, 1996 CanLII 217 (S.C.C.) – 1996-02-22 Canada – Supreme Court of Canada taxable – income – employment – retiring allowance – sources [cited by 285 cases]
  • Neuman v. M.N.R., 1998 CanLII 826 (S.C.C.) – 1998-05-21 Canada – Supreme Court of Canada dividend income – non-arm's length transactions – reassessed taxpayer – shares – corporation [cited by 47 cases]
  • 65302 British Columbia Ltd. v. Canada, 1999 CanLII 639 (S.C.C.) – 1999-11-25 Canada – Supreme Court of Canada deduction – over-quota levy – fines – expenses – income [cited by 97 cases]
  • Tennant v. M.N.R., 1996 CanLII 218 (S.C.C.) – 1996-02-22 Canada – Supreme Court of Canada shares – deduction – taxpayer – borrowed – interest [cited by 29 cases]
  • Tsiaprailis v. Canada, 2005 SCC 8 (CanLII) – 2005-02-25 Canada – Supreme Court of Canada lump sum payment – settlement – insurance – taxable – surrogatum principle [cited by 12 cases]
  • R. v. Jarvis, 2002 SCC 73 (CanLII) – 2002-11-21 Canada – Supreme Court of Canada taxpayer – investigation – auditor – penal liability – tax [cited by 130 cases]
  • Stewart v. Canada, 2002 SCC 46 (CanLII) – 2002-05-23 Canada – Supreme Court of Canada reasonable expectation of profit – taxpayer – source of income – business – deduction [cited by 94 cases]
  • Placer Dome Canada Ltd. v. Ontario (Minister of Finance), 2006 SCC 20 (CanLII) – 2006-05-25 Canada – Supreme Court of Canada output of a mine – transactions – statutory definition of hedging – price – delivery [cited by 30 cases]
  • Symes v. Canada, 1993 CanLII 55 (S.C.C.) – 1993-12-16 Canada – Supreme Court of Canada deduction – child care expenses – women – taxpayer – income [cited by 189 cases]
  • Friesen v. Canada, 1995 CanLII 62 (S.C.C.) – 1995-09-21 Canada – Supreme Court of Canada inventory – adventure in the nature – business – taxpayer – nature of trade [cited by 203 cases]
  • Hickman Motors Ltd. v. Canada, 1997 CanLII 357 (S.C.C.) – 1997-06-26 Canada – Supreme Court of Canada income – business – property – capital cost – assets [cited by 137 cases]
  • Ludco Enterprises Ltd. v. Canada, 2001 SCC 62 (CanLII) – 2001-09-28 Canada – Supreme Court of Canada income – deductible – taxpayer – borrowed money – interest [cited by 68 cases]
  • Cunningham v. Wheeler; Cooper v. Miller; Shanks v. McNee, 1994 CanLII 120 (S.C.C.) – 1994-03-17 Canada – Supreme Court of Canada benefits – insurance – wages – deducted – disability [cited by 142 cases]
  • Imperial Oil Ltd. v. Canada; Inco Ltd. v. Canada, 2006 SCC 46 (CanLII) – 2006-10-20 Canada – Supreme Court of Canada foreign currency – amount – taxpayer – deduction – dollars [cited by 19 cases]
  • City of Port Coquitlam v. Wilson, 1922 CanLII 17 (S.C.C.) – 1922-12-19 Canada – Supreme Court of Canada fire – stove – jury – pipe – servant
  • Western Canada Power Co. v. Bergklint, 1916 CanLII 37 (S.C.C.) – 1916-12-30 Canada – Supreme Court of Canada workmen – cliff – work – superintendent – negligence
  • Canderel Ltd. v. Canada, 1998 CanLII 846 (S.C.C.) – 1998-02-12 Canada – Supreme Court of Canada accurate picture – taxpayer – well-accepted business principles – income – matching [cited by 72 cases]
  • Stubart Investments Ltd. v. The Queen, 1984 CanLII 20 (S.C.C.) – 1984-06-07 Canada – Supreme Court of Canada taxpayer – tax – transaction – sham – business [cited by 327 cases]
  • Citations by Federal Court of Appeal 
    (http://www.canlii.org)

[As at December 31, 2008]

  • Chavali v. Canada, 2002 FCA 208 (CanLII) – 2002-05-21 Canada – Federal Court of Appeal three-prong – motion – evidence – jurisprudence – discoverable
  • Trengrove Developments Inc. (94-2663 (Gst) G) v. Canada, 1998 CanLII 7812 (F.C.A.) – 1998-05-21 Canada – Federal Court of Appeal concise – analyzed – interfering – persuaded – delivered
  • Canada v. Sherway Centre Ltd. (C.A.), 1998 CanLII 9046 (F.C.A.) – 1998-02-05 Canada – Federal Court of Appeal participatory interest – deduction – payments – borrowing money – principal [cited by 1 case]
  • M.N.R. v. Phillips (C.A ), 1994 CanLII 3468 (F.C.A.) – 1994-03-14 Canada – Federal Court of Appeal employee – house – payment – relocation – taxable [cited by 4 cases]
  • Scott v. Canada, 1998 CanLII 8141 (F.C.A.) – 1998-07-23 Canada – Federal Court of Appeal deduction – expense – food – beverages – business [cited by 1 case]
  • OSFC Holdings Ltd. v. Canada (C.A.), 2001 FCA 260 (CanLII) – 2001-09-11 Canada – Federal Court of Appeal series – tax benefit – avoidance transaction – arm's length – loss [cited by 16 cases]
  • Jenner v. Canada, 2008 FCA 196 (CanLII) – 2008-05-29 Canada – Federal Court of Appeal business – passenger vehicle – lease – activité – income
  • Lamont Management Ltd. v. Canada (C.A.), 2000 CanLII 17131 (F.C.A.) – 2000-04-19 Canada – Federal Court of Appeal corporation – dividend – foreign non-affiliate – safe income – foreign affiliate
  • Singleton v. Canada (C.A.), 1999 CanLII 9352 (F.C.A.) – 1999-06-11 Canada – Federal Court of Appeal commutateur inconnu – transaction – borrowed funds – deduction – taxpayer [cited by 2 cases]
  • Canada v. Imperial Oil Ltd., 2004 FCA 36 (CanLII) – 2004-01-26 Canada – Federal Court of Appeal loan – société – investment allowance – misuse – capital
  • Bellingham v. Canada (C.A.), 1995 CanLII 3544 (F.C.A.) – 1995-11-30 Canada – Federal Court of Appeal taxpayer – income – additional interest – expropriating authority – award [cited by 5 cases]
  • Bernick v. Canada, 2004 FCA 191 (CanLII) – 2004-05-13 Canada – Federal Court of Appeal accounting method – maturity value – zero coupon bonds – financial statements – income [cited by 1 case]
  • Gulfmark Offshore N.S. Limited v. Canada, 2007 FCA 302 (CanLII) – 2007-09-21 Canada – Federal Court of Appeal ship – interest expenses – carrying on activities – business through a permanent establishment – bareboat
  • Canada v. Larsson, 1997 CanLII 6178 (C.A.F.) – 1997-08-05 Canada – Federal Court of Appeal versements hypothécaires – impôt – réputés – quatrième – bénéficiaire
  • Corbett v. Canada (C.A.), 1996 CanLII 3849 (F.C.A.) – 1996-10-30 Canada – Federal Court of Appeal taxpayer – property – deduction – amount – profit [cited by 7 cases]
  • Canada v. Placer Dome Inc. (C.A.), 1996 CanLII 4094 (F.C.A.) – 1996-11-05 Canada – Federal Court of Appeal dividend – capital gain – transaction – purpose – taxpayer [cited by 5 cases]
  • 74712 Alberta Ltd. v. M.N.R. (C.A.), 1997 CanLII 6326 (F.C.A.) – 1997-01-29 Canada – Federal Court of Appeal borrowed – taxpayer – deduction – guarantee – income [cited by 5 cases]
  • Canada (Attorney General) v. Hoefele (C.A.), 1995 CanLII 3541 (F.C.A.) – 1995-10-11 Canada – Federal Court of Appeal taxpayers – relocation – taxable – mortgage interest subsidy – benefit [cited by 8 cases]
  • Canada v. Shell Canada Ltd. (C.A.), 1998 CanLII 9045 (F.C.A.) – 1998-02-18 Canada – Federal Court of Appeal borrowed – interest – taxpayer – deduction – rate [cited by 6 cases]
  • Hsu v. The Queen, 2001 FCA 240 (CanLII) – 2001-07-24 Canada – Federal Court of Appeal reassessments – taxpayer – income – net worth method – auditor [cited by 7 cases]
  • Canada v. Nunn, 2006 CAF 403 (CanLII) – 2006-12-08 Canada – Federal Court of Appeal régimes enregistrés d'épargne-retraite – société – impôt – doctrine du trompe-l oeil – utilisé
  • Rich v. Canada (C.A.), 2003 FCA 38 (CanLII) – 2003-01-27 Canada – Federal Court of Appeal debt – taxpayer – loan – proactive steps – bad [cited by 12 cases]
  • Canada v. Neuman (C.A.), 1996 CanLII 4085 (F.C.A.) – 1996-08-23 Canada – Federal Court of Appeal dividend – shares – declared – wife – non-arm's length transactions [cited by 1 case]
  • Soper v. Canada (C.A.), 1997 CanLII 6352 (F.C.A.) – 1997-06-27 Canada – Federal Court of Appeal director – taxpayer – standard of care – remittances – skill [cited by 77 cases]
  • Wagg v. Canada (F.C.A.), 2003 FCA 303 (CanLII) – 2003-07-11 Canada – Federal Court of Appeal input tax credits – adjournment – can – want – recess [cited by 10 cases]
  • Cudd Pressure Control Inc. v. Canada, 1998 CanLII 8590 (F.C.A.) – 1998-10-19 Canada – Federal Court of Appeal permanent establishment – snubbing units – deduction – enterprise – notional rent [cited by 1 case]
  • Hudon v. Canada, 2001 FCA 320 (CanLII) – 2001-10-29 Canada – Federal Court of Appeal hydroelectric – carrying on business – corporation – electricity – liée [cited by 6 cases]
  • Hammill v. Canada, 2005 FCA 252 (CanLII) – 2005-07-07 Canada – Federal Court of Appeal gems – expenses – scam – inventory – business [cited by 4 cases]
  • Cardella v. Canada, 2001 FCA 39 (CanLII) – 2001-02-26 Canada – Federal Court of Appeal reasonable expectation of profit – income – adventure in the nature – partnership – taxpayer [cited by 2 cases]
  • Canada v. Canderel Ltd. ( C.A. ), 1995 CanLII 3572 (F.C.A.) – 1995-02-13 Canada – Federal Court of Appeal ftnote – taxpayer – deduction – income – expenditure [cited by 5 cases]
  • La Capitale, Compagnie d'Assurance Générale v. Canada, 1998 CanLII 7390 (F.C.A.) – 1998-02-06 Canada – Federal Court of Appeal premium – insurance – income – amount – contract
  • Canada v. Gifford, 2002 FCA 301 (CanLII) – 2002-08-12 Canada – Federal Court of Appeal capital expenditure – clients – deductibility – interest – payment on account of capital [cited by 2 cases]
  • Canada v. Agazarian, 2004 FCA 32 (CanLII) – 2004-04-23 Canada – Federal Court of Appeal normal reassessment period – taxpayer – cotisation – impôt – taxation [cited by 1 case]
  • 2529-1915 Québec Inc. v. Canada, 2008 FCA 398 (CanLII) – 2008-12-12 Canada – Federal Court of Appeal dividends – subsidiary – sham – corporations – shares
  • Canada v. Nova Corp. of Alberta, 1997 CanLII 6069 (C.A.F.) – 1997-05-01 Canada – Federal Court of Appeal actions privilégiées – base rajusté – perte – société – déclarées
  • St-Hilaire v. Canada (Attorney General) (C.A.), 2001 FCA 63 (CanLII) – 2001-03-19 Canada – Federal Court of Appeal unworthiness – manslaughter – murder – attempt on the life – death [cited by 8 cases]

Coursese

  • Past Exams CML 3204
  • Basic Taxation Course

Books

Books Published

  • Canadian Taxation, Richard De Boo Limited, Toronto:
     1st ed.  1979
     2nd   1981
  • The Taxation of Capital Gains, Butterworths, 1983.
  • The Fundamentals of Canadian Income Tax, Carswell Legal Publishers, Toronto:
     1st ed.  1985
     2nd  1986
     3rd  1989
     4th  1993
     5th  1995
     6th  2000
     7th  2002
     8th  2004
     9th   2006
  • Tax Avoidance: The General Anti Avoidance Rule, Carswell Legal Publishers, Toronto, 1989
  • Canadian International Taxation, Carswell Legal Publishers, Toronto: 1995
  • Canada’s Tax Treaties, Butterworths, 1996
  • The Essentials of Income Tax Law, Irwin Law, 1997
  • The Canada - US Tax Treaty, Lexis Nexis, Canada, 2005
  • The Canada – UK Tax Treaty, Lexis Nexis, Canada, 2006
  • The Canada – India Tax Treaty, Lexis Nexis, Canada, 2007
  • Halsbury’s Laws of Canada (Personal Taxation), 2008
  • Halsbury’s Laws of Canada (Corporate Taxation), 2008

Books and Looseleafs

  • Essays on Canadian Taxation, (Co-editor) Richard De Boo (1978).
  • Canadian Taxation, (Co-editor) Richard De Boo Ltd. (1981).
  • The Taxation of Capital Gains, 251 pps. (Butterworths, 1983).
  • The Fundamentals of Canadian Income Tax, (Carswell Thomson Professional Publishers,
    Toronto), (5th Ed. 1995).
  • Tax Avoidance: The General Anti-Avoidance Rule, 188 pps. (Carswell Legal Publishers,
    Toronto) 1990.
  • Canadian International Taxation, Carswell Legal Publications, Toronto, 1995 (Looseleaf)
  • Canada's Tax Treaties, Butterworths Canada, 1996 (Looseleaf)

Case Law

  • Antosko v. Minister of National Revenue (May 26, 1994)
  • Bronfman Trust v. R. (January 29, 1987)
  • C.L.E. v. B.M.R. (June 18, 2010)
  • Canada Trustco Mortgage Co. v. R. (October 19, 2005)
  • Canderel Ltd. v. R. (February 12, 1998)
  • Cumming v. Minister of National Revenue (November 8, 1967)
  • Denison Mines Ltd. v. Minister of National Revenue (October 1, 1974)
  • Duke of Westminster v. Commissioners of Inland Revenue (May 7, 1935)
  • Furniss v. Dawson (February 9, 1984)
  • Lipson v. Canada 2009 SCC 1 (January 8, 2009)
  • Minister of National Revenue v. Eldridge (November 27, 1964)
  • R. v. Fries (January 31, 1983)
  • Friesen (J.) v. Canada (September 21, 1995)
  • Garron Family Trust (Trustee of) v. R. (September 10, 2009)
  • Gernhardt v. R. (July 26, 1996)
  • Krull v. Canada (Attorney General) (October 11, 1995)
  • Irrigation Industries Ltd. v. Minister of National Revenue (March 26, 1962)
  • Johns-Manville Can. Inc. v. R. (July 31, 1985)
  • Kellogg Co. of Canada v. Minister of National Revenue (March 31, 1942)
  • Laidler v. Perry (Inspector of Taxes) (April 8, 1965)
  • Lipson v. R. (March 16, 2007)
  • Lipson v. R. (January 8, 2009)
  • Ludmer c. Ministre du Revenu national (September 28, 2001)
  • Mathew v. R. (October 19, 2005)
  • McBurney v. R. (September 25, 1985)
  • Neuman v. Minister of National Revenue (May 21, 1998)
  • No. 476 v. Minister of National Revenue (November 21, 1960)  
  • Rachfalowski v. R. (May 15, 2008)
  • Ransom v. Minister of National Revenue (August 18, 1967)
  • Royal Trust Co. v. Minister of National Revenue (January 22, 1957)
  • R. v. Savage (November 24, 1983)  
  • Schwartz v. R. (February 22, 1996)
  • Scott v. R. (July 23, 1998)
  • Shell Ltd. v. R. (October 15, 1999)
  • Shih v. R. (March 31, 2000)
  • Singleton v. R. (September 28, 2001)
  • Stewart v. R. (May 23, 2002)
  • Strother v. 3464920 Canada Inc. (June 1, 2007)
  • Stubart Investments Ltd. v. R. (June 7, 1984)
  • Symes v. R. (December 16, 1993)
  • Minister of National Revenue v. Taylor (October 16, 1956)
  • Thomson v. Minister of National Revenue (January 24, 1946)
  • Toronto College Park Ltd. v. R. (February 12, 1998)
  • Toth v. R. (January 15, 2004)
  • Tsiaprailis v. R. (February 25, 2005)
  • Unit Construction Co., Ltd. v. Bullock (Inspector of Taxes) (November 30, 1959)
  • Wiebe Door Services Ltd. c. Ministre de Revenu national (June 18, 1986)
  • Will-Kare Paving & Contracting Ltd. v. R. (July 20, 2000)

Tax Treaties

  • Using Beneficial Ownership to Prevent Treaty Shopping
  • Withholding Rates Chart
  • OECD Model Tax Convention
  • OECD and UN Models Compared
  • 2008 Update to the OECD Model
  • Australia US Treaty
  • Withholding Tax Rates In Treaty Countries
  • Australia Canada Treaty
  • 2008 Update to the OECD Model

Selected Journal Articles & Case Comments

  • “The International Income Taxation of Electronic Commerce”, Certified General Accountants Association of Canada, 1999
  • “Selective Tax Breaks”, (1998-99), 9 Can. Current Tax, No. 11, August 1999
  • “Rocky Stock Markets”, (1998-99), 9 Can. Current Tax, No. 10, July 1999
  • “Limited Liability Partnerships”, (1998-99), 9 Can. Current Tax, No. 9, June 1999
  • “Tax Rage”, (1998-99), 9 Can. Current Tax, No. 8, May 1999
  • “Taxation of Personal Injury Awards”, (1998-99), 9 Can. Current Tax, No. 6, March 1999
  • “Bribery and Corruption” (1998-99), 9 Can. Current Tax, No. 6, March 1999
  • “The Distinction Between Business and Personal Expenses”, (1998-99), 9 Can. Current Tax, No. 3, December 1998
  • “Foreign Income Reporting Requirements”, (1997-98), 8 Can. Current Tax, No. 12, September 1998
  • “The Elusive Interest Deduction”, (1997-98), 8 Can. Current Tax, No. 9,June 1998
  • “Taxation of Electronic Commerce”, (1997-98, 8 Can. Current Tax, No. 6, March 1998.
  • “Offshore Trusts”, (1997-98), 8 Can. Current Tax, No.  5, February 1998.
  • “Purposive Interpretation as a Weapon Against Tax Avoidance”, Canadian Current Tax, Vol. 8, No. 2, November 1997
  • "Avoiding Double Taxation" "Une Sarl Aux Etats-Unis", CGA Magazine, October 1994, p. 45.
  • "Moving the Goal Posts on Interest Deductibility", CGA Magazine, April 1994, p. 30.
  • "Corporate Share Capital Structures and Income Splitting: McClurg v. Canada", Canadian Business Law Journal, Vol. 21, No. 3 (March 1993).
  • "Developments in the Law of Income Taxation:  The 1986-87 Term" (1988), 10 Supreme Court Law Review, p. 297;
  • "Developments in the Law of Income Taxation:  The 1985-86 Term" (1987), 9 Supreme Court Law Review, p. 487;
  • "Determining the `Fair Value' of Corporate Shares", Canadian Business Law Journal, Vol. 13, No. 2, p. 123 (1987);
  • "Determining the Value of Company Shares", The Company Lawyer, Vol. 8, No. 2, p. 66 (1987);
  • "A Law That Taxes Our Understanding", Canadian Lawyer, December 1986, p. 10;
  • "The Settlement Privilege", Canadian Current Tax, Volume 6, No. 9, June 1996
  • "Tax Rates and Bracket Creep", Canadian Current Tax, Volume 6, No. 6, March 1996
  • "Administrative Concessions on Non-Taxable Perks", Volume 6, No. 6, March 1996
  • "Corporate Taxation in the NAFTA Countries", CGA Magazine, February 1996 p.45
  • "Resulting Trusts", Canadian Current Tax, Volume 6, No. 5, February 1996
  • "The Taxation of Relocation Payments", Canadian Current Tax, Volume 6, No. 4, January 1996
  • "Corporate Taxation in the NAFTA Countries" Three Parts in CGA Magazine, December 1995 - February 1996
  • "The High Cost of Tax Financing", Canadian Current Tax, December 1995, Volume 6, No. 3
  • "The Netherlands as an Offshore Centre", Canadian Current Tax, December 1995, Volume 6, No. 3
  • "First GAAR Case an Easy Win for Revenue" Canadian Current Tax, October 1995, Volume 6, No. 1
  • "Jersey the Oldest Tax Haven", Canadian Current Tax, September 1995, Volume 5, no. 12
  • "What Constitutes a Business?" Canadian Current Tax, Canadian Current Tax, Volume 5, No. 9
  • "The Long Arm of Section 160", CGA Magazine, May 1995, p. 32
  • "New Directions in Tax Interpretation", Canadian Current Tax, February 1995, Volume 5, No. 5
  • "Child Support Payments Not Deductible without Custody", Canadian Current Tax, January 1995, Volume 5, No. 4
  • "Spousal Cohabitation", Canadian Current Tax, December 1994, Volume 5, No. 3
  • "Income Taxation of Individuals in NAFTA Countries", Two Parts in CGA Magazine, February - March, 1995
  • "Surrogatum Principle Applies to Employment Source Income", Canadian Current Tax, October 1994, Volume 5, No. 1
  • "Avoiding Double Taxation" "Une Sarl Aux Etats-Unis", CGA Magazine, October 1994, p. 45
  • "Supreme Court Restores Balance in Statutory Interpretation", Canadian Current Tax, Vol. 4, No. 21 (September 1994)
  • "Update on International Taxation", Canadian Current Tax, Vol. 4, No. 21 (September 1994)
  • "United States Supreme Court Upholds Unitary Taxation", Canadian Current Tax, Vol. 4, No. 20 (August 1994)
  • "The Scope of Employment Benefits", Canadian Current Tax, Vol. 4, No. 18 (June 1994)
  • "Retiring Allowances", Canadian Current Tax, Vol. 4, No. 17 (May 1994)
  • "Moving the Goal Posts on Interest Deductibility", CGA Magazine, April 1994, p. 30
  • "Income Splitting Corporate Structures", Canadian Current Tax, Vol. 4, No. 15 (March 1994)
  • "Does Supreme Court Expand Deductibility of Business Expenses in Symes?", Canadian Current Tax, Vol. 4, No. 14 (February 1994)
  • "Carrying On Business In The United States: Choice of Form of Organization", Canadian Current Tax, Vol. 4, No. 13 (January 1994)
  • "Residence for United States Income Tax", Canadian Current Tax, Vol. 4, No. 12 ( December 1993)
  • "Cross Border Pensions", Canadian Current Tax, Vol. 4, No. 10 (October 1993)
  • "Stock Options Exercised After Becoming Non-Resident", Canadian Current Tax, Vol. 4, No. 9 (September 1993)
  • "International Employment Income", Canadian Current Tax, Vol. 4, No. 8 (August 1993)
  • "Liability of Shareholders for Corporate Taxes", Canadian Current Tax, Vol. 4, No. 7 (July 1993)
  • "GAAR and the Purification of Corporations for the Capital Gains Exemption: Part I", Canadian Current Tax, Vol. 4, No. 6 (June 1993)
  • "Interest Deductibility: More Form Over Substance", Canadian Current Tax, Vol. 4, No. 5 (May 1993)
  • "Corporate Share Capital Structures and Income Splitting: McClurg v. Canada", Canadian Business Law Journal, Vol. 21, No. 3 (March 1993)
  • "House of Lords Permits Use of Parliamentary Materials in Statutory Construction", Canadian Current Tax, Vol. 4, No. 3, (March 1993)
  • "Using the Capital Gains Exemption for Matrimonial Settlements", Canadian Current Tax, Vol. 4, No. 2 (February 1993)
  • "Converting Salary into Management Fees", Canadian Current Tax, Vol. 4, No. 1 (January 1993)
  • "Personal Liability of Shareholders for Unpaid Corporate Taxes", Canadian Current Tax. Vol. 3, No. 22, p. C 81 (October 1991)
  • "Corporate Share Capital Structures and Income Splitting", Canadian Current Tax, Vol. 3, No. 20 (August 1991).
  • "Dividend Sprinkling Strategies", CGA Magazine, July 1991, Vol. 25, No. 7, p. 49.
  • "Who Benefits? Taxation of Shareholder Benefits", CGA Magazine, January 1991, Vol. 25, No. 1, p. 45.
  • "Supreme Court of Canada Strikes a Blow for Taxpayers, Canadian Current Tax, Vol. 3, No. 12 (December 1990) p. J-55.
  • "How Do Anti-Avoidance Rules Affect Pension Plans?" Benefits Canada, November 1990, Vol. 14, No. 9, P. 13.
  • "Shareholder Benefits", Canadian Current Tax, Vol. 3, No. 10 (October 1990) p. C-33.
  • "Guardian of the Law: The GST General Anti-Avoidance Rule", CGA Magazine, September 1990, Vol. 24, No. 9, p. 61.
  • "Tax Act Provides Incentives for Charitable Donations" Law Times, June 18, 1990.
  • "Step Transactions and the GAAR", CGA Magazine, July 1990, p. 34 (Part I); and August 1990, p. 25 (Part II).
  • "Transferring Assets to Avoid Taxes Can Harm Innocent Third Parties", Law Times, April 23, 1990.
  • "Matrimonial Settlements Pose Taxing Problem", Law Times, April 9, 1990.
  • "To Love, Honor or Pay", CGA Magazine, April 1990, p. 28.
  • "Structuring Matrimonial Settlements", Canadian Current Tax, Vol. 3, No. 3 (March 1990) p. J-19.
  • "Deducting Those Exotic Convention Expenses", Law Times (Feb. 4, 1990).
  • "Income Splitting Still Attractive Option for Taxpayers", Law Times (February 19-25, 1990) p. 18.
  • "The Power of Influence", CGA Magazine, February 1990, p. 48.
  • "Spousal Payments", CGA Magazine, Sept. 1989, Vol. 23, No. 9, p. 44.
  • "Lump Sum Matrimonial Settlements May Be Tax Deductible", Canadian Current Tax,
  • Vol. 2, No. 32, August 1989.
  • "Look at Leasing"/Credit-Bail, CGA Magazine, July 1989, p. 15.
  • "Off-Shore Business Centres: The Barbados International Business Company", Canadian Current Tax, May 1989, Vol. 2, No. 29.
  • "Tax Havens: Black Sheep or Sleeping Beauties?" Canadian Current Tax, Vol. 2, No. 27 (March 1989).
  • "Federal Court Relaxes Rules on Deductibility of Fines and Penalties", Canadian Current Tax, Vol. 2, No. 20, p. J99 (1988).
  • "GAAR: The Ultimate Tax Avoidance Weapon", Canadian Current Tax, Vol. 2, No. 16, p. C75 (1988).
  • "Shareholder Agreements (Inter vivos)", CGA Magazine, November 1988, p. 21.
  • "Developments in the Law of Income Taxation: The 1986-87 Term" (1988), 10 Supreme Court Law Review, p. 297.
  • "Take a Break and Save Tax Dollars", Canadian Lawyer, November 1988, p. 39.
  • "Hard Times for Middle Incomes?", Canadian Lawyer, February 1988.
  • "Buy-sell Shareholders' Agreements", CGA Magazine, March 1988.
  • "Canadian Income Taxation: A Brief History", CGA Magazine, May 1988.
  • "How to Make Your Interest Tax Deductible", Canadian Lawyer, May 1988.
  • "Developments in the Law of Income Taxation: The 1985-86 Term" (1987), 9 Supreme Court Law Review, p. 487.
  • "Determining the 'Fair Value' of Corporate Shares", Canadian Business Law Journal, Vol. 13, No. 2, p. 123 (1987).
  • "Extending Time to File Notice of Appeal", Canadian Current Tax, Vol. 2, No. 8 (1987).
  • "Illegal Search & Seizure: What Do We Do With the Tainted Fruit", Canadian Current Tax, Vol. 2, No. 7 (1987).
  • "Obtaining Extension of Time to File Notice of Objection: The Palm Tree Begins to Wither", Canadian Current Tax, Vol. 2, No. 4 (1987).
  • "Importing a Non-Resident Corporation's Losses", Canadian Current Tax, Vol. 2, No. 4.
  • "Income Tax Considerations Excluded in an Accounting for Profits", Canadian Current
  • Tax, Vol. 2, No. 2 (1987).
  • "The Meaning of 'Minus' in Tax Law", Canadian Current Tax, Vol. 2, No. 2 (1987).
  • "Determining the Value of Company Shares", The Company Lawyer, Vol. 8, No. 2, p. 66 (1987).
  • "Stock Option Plans", Canadian Current Tax, Vol. 1, No. 36 (1986).
  • "Taxation of Employee Benefits", Canadian Current Tax, Vol. 1, No. 35 (1986).
  • "A Law That Taxes Our Understanding", Canadian Lawyer, December 1986, p. 10.
  • "Windfall Gains and Inducement Payments", Canadian Current Tax, Vol. 1, No. 33 (1986).
  • "Sale of Franchises: Receipts on Account of Eligible Capital Property or Income from Business", Canadian Current Tax, Vol. 1, No. 32 (1986).
  • "Meaning of 'Allowance'", Canadian Current Tax, Vol. 1, No. 30 (1986).
  • "Indirect Payments and Transfers of Income", Canadian Current Tax, Vol. 1, No. 28 (1986).
  • "The Demise of the Strict Interpretation Rule", Canadian Current Tax, Vol. 1, No. 28 (1986).
  • "Charitable Donations: What is a 'Charitable Purpose'?", Canadian Current Tax, Vol. 1, No. 32 (1986).
  • "Deductibility of Legal and Accounting Fees in Defending Tax Evasion Charges", Canadian Current Tax, Vol. 1, No. 26 (1986).
  • "Charitable Donations: What Constitutes a 'Gift'?", Canadian Current Tax, Vol. 1, No. 3 (1985).
  • "Notice of Objection: Extension of Time for Ignorance of the Law", Canadian Current Tax, Vol. 1, No. 23 (1985).
  • "Common Law Piercing of the Corporate Veil To Individual Shareholders", Canadian Current Tax, Vol. 1, No. 22 (1985).
  • "Minimum Tax: Is the Light Worth the Candle?", Ontario Lawyers Weekly (1985) 5 Ont. Lawyers Wkly, No. 9, 6.
  • "Payments In Kind and Barter", Canadian Current Tax, Vol. 1, No. 20 (1985).
  • "Farm Losses - Chief Source of Income", Canadian Current Tax, Vol. 1, No. 19 (1985).
  • "Re Campeau Family Trust: Two Wrongs Make a Right", Estates and Trusts Quarterly, Vol. 7 (1985), p. 65.
  • "The Taxation of Damages", Canadian Current Tax, Vol. 1, Nos. 18 and 19 (1985).
  • "Corporate Share Structures and Estate Planning", Estate and Trusts Quarterly, Vol. 6 (1982-84), p. 168.
  • "The Demise of the Business Purpose Test", Canadian Current Tax, Vol. 1, No. 9 (September 1984).
  • "Characterization of 'Income from Business and 'Income from Property"' Canadian Current Tax, Vol. 1, No. 8 (August 1984).
  • "Liability of Directors for Corporate Taxes", Canadian Current Tax, Vol. 1, No. 6 (June 1984).
  • "Is There a Choice of Methods in Accounting for Interest Expenses", Canadian Current Tax , Vol. 1, No. 5 (May 1984).
  • "Step Transactions: An Emerging Doctrine or an Extension of the Business Purpose Test", Canadian Current Tax, Vol. 1, No. 4 (April 1984).
  • Comment on Bronfman Trust v. The Queen, Estates and Trusts Quarterly, Vol. 6, 1982-84, p. 247.
  • "Employee Benefits", Canadian Current Tax, Vol. 1, No. 2 (February 1984).
  • "Testamentary Transfers of Capital Property Between Spouses: When Does Property 'Vest Indefeasibly'?", Canadian Current Tax, Vol. 1, No. 1 (January 1984).
  • "Illegally Obtained Evidence and the Canadian Charter of Rights and Freedoms", Canadian Current Tax, October 1983, Issues 41 and 42.
  • "Personal services business income: the 'incorporated' employee / Revenus tires d'une entreprise de services personnels: L'employe 'constitue en societe',
  • " CGA Magazine,Vol. 17, No. 10, October 1983.
  • "Alimony Payments: 'Payable on a Periodic Basis"', Canadian Current Tax, October 1983, Issues 39 and 40.
  • "Search and Seizure", Canadian Current Tax, September 1983, Issues 35 and 36.
  • "Corporate Share Structures and Estate Planning", Estates and Trusts Quarterly, Vol. 6, 1982-84, p. 168.
  • "Interest expenses/Frais d'interet", CGA Magazine, Vol. 17, No. 7, July 1983.
  • "Deductibility of Interest Expense", Canadian Current Tax (Butterworths) July 1983.
  • "Taxing farm property/L'imposition de biens agricoles", CGA Magazine, Vol. 17, No. 6, June 1983.
  • "Testamentary Transfers of Capital Property Between Spouses"/Les transferts de biens a un conjoint: Les regles d'attribution, CGA Magazine, Vol. 17, No. 4, April 1983.
  • "Property Transfers Between Spouses: The Attribution Rules"/des transferts de biens a un conjoint: Transferts par testament, CGA Magazine, Vol. 17, No. 3, March 1983.
  • "Inter-Vivos Transfers of Capital Property Between Spouses"/des transferts de biens a un conjoint: transferts entre vifs, CGA Magazine, Vol. 17, No. 2, February 1983.
  • "Recent Changes in the Taxation of Employees", Canadian Current Tax (Butterworths, January 1983).
  • "Income From Office and Employment", Materials on Canadian Income Tax, 5th Ed., Richard De Boo Ltd., (1983).
  • "The Determination of Capital Gains", Canadian Current Tax (Butterworths, December 1982).
  • "Inter-vivos Transfer of Farm Property by a Farmer to His Child ", Canadian Current Tax (Butterworths, December 1982).
  • "Transfer of Shares of the Capital Stock of a Small Business Corporation", Canadian Current Tax (Butterworths, December 1982).
  • "Charities and Political Activities", Canadian Taxation, Vol. 3, No. 3 (Fall 1981).
  • "A Framework for the Formulation of Income Tax Policy", Canadian Taxation, Richard De Boo Ltd. (1981).
  • "The Measurement of Income: General Principles", Canadian Taxation, Richard De Boo Ltd. (1981).
  • "Universality and Selectivity in Tax-Transfer Programs", Canadian Taxation, Vol. 2, No. 3 (Fall 1980).
  • "Taxation of Private Corporations and Their Shareholders", Canadian Income Tax (Butterworths, 1980).
  • "Taxation of Corporations and Their Shareholders", Canadian Income Tax (Butterworths, 1980).
  • "Capital Gains", Canadian Income Tax (Butterworths, 1979).
  • "Taxation of Public Corporations and Their Shareholders", Canadian Income Tax (Butterworths, 1979).
  • "Intra-Family Property Transfers: Income Tax and Estate Planning Aspects, Tax Planning and Management, Canadian Income Tax (Butterworths, 1979).
  • Case Annotation on Cirella v. The Queen, Vol. 4 C.C.L.T., p. 66 (May 1978).
  • "Tax Factors in Personal Injury and Fatal Accident Cases: A Plea for Reform", Osgoode Hall Law Journal, Vol. 16, No. 3, p. 723 (November 1978).
  • "Public Policy Limitations on the Deductibility of Fines and Penalties: Judicial Inertia", Osgoode Hall Law Journal, Vol. 16, No. 1, p. 19 (June 1978).
  • "Tax Planning for Dispositions of Depreciable Property at Death", Alberta Law Review, Vol. xv, No. 2, p. 313 (1977).
  • "Characterization of Wrongful Dismissal Awards for Income Tax", McGill Law Journal, Vol. 23, No. 1, p. 43 (1977).
  • Case Comment on Mastronardi v. The Queen, 76 D.T.C. 6306, Estates and Trusts Quarterly, Vol. 3, No. 4 (March 1977).
  • "Spousal Trusts", Nova Scotia Law News, Vol. 3, No. 4, p. 5 (Feb. 1977).
  • "Intra-Family Property Transfers", Nova Scotia Law News, Vol. 3, No. 2, p. 2 (Oct. 1976).
  • "Taxation of Personal Injury Awards: A Wiry Methuselah", Dalhousie Law Journal, Vol. 3, No. 2, p. 385 (Oct. 1976).
  • "Tax Consequences of Compensation Policies", Alberta Law Review, Vol. xiii, No. 2, p. 111 (1975).
  • "Corporate Distributions to Stockholders", Alberta Law Review, Vol. xii, No. 3, p. 301 (1974).
  • "An Analysis of General Movements in Stock Prices", Journal of Business Administration, Vol. 4, No. 1, p. 35 (U.B.C., Fall, 1972).

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