David D Robertson

Formerly counsel with the Canadian Department of Justice Tax Law Services, David’s experience includes resolving all forms of tax disputes – through rulings, objections, appeals, or settlement – including international transfer pricing, general anti-avoidance rule (GAAR) assessments (federal & provincial), residency & permanent establishment issues, partnership deferral arrangements, valuation, thin-capitalization, treaty & statutory interpretation, complex corporate reorganizations, directors’ liability, debt forgiveness, employee & shareholder benefits, GST/HST, PST, international transportation, native tax exemptions, insurance premium taxes, as well as tax collection, taxpayer relief, and third-party liability assessments.