Dominic Belley

Practice Areas

Dominic Belley is a tax litigator.

In 25 years of practice, Dominic has argued over 200 cases on behalf of taxpayers in seven out of 10 Canadian provinces. He has represented taxpayers against federal, provincial and municipal tax authorities in civil, commercial, criminal and constitutional matters before the Court of Québec, the Québec Superior Court, the Québec Court of Appeal, the B.C. Supreme Court, the Alberta Court of King’s Bench, the Ontario Superior Court of Justice, the Nova Scotia Supreme Court, the Tax Court of Canada, the Federal Court and the Federal Court of Appeal.

Dominic has argued five cases before the Supreme Court of Canada as lead counsel for the appellant, the respondent and the intervener.

His domestic tax experience includes the general anti-avoidance rule (GAAR), tax on capital, the goods and services tax (GST), interest deductibility, hybrid transactions, the capital gains exemption, capital cost allowance, debt forgiveness, taxation of partnerships, trusts and estates, scientific research and experimental development (SR&ED), real estate, stock options, protection of tax information and cancellation of penalties.

His international tax experience includes transfer pricing, foreign accrual property income (FAPI), residency, corporate migrations, the thin capitalization rules, de facto control by non-residents, international and inter-provincial allocation of income, anti-discrimination treaty provisions, and access to and protection of tax information through tax conventions.

His experience in Aboriginal taxation includes negotiating an agreement with an Indian band on the application and administration of on-reserve taxes levied against non-Aboriginal taxpayers.