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Stevan Novoselac is the national leader of the Gowlings Tax Dispute Resolution team, an integral part of the firm's Tax Practice Group. He is also the Taxand representative for tax litigation in Canada.
Stevan helps taxpayers across Canada resolve all kinds of tax disputes, including voluntary disclosures, requirements for information, audits, objections, appeals, collections issues, taxpayer relief applications, rectification orders and remission orders.
Stevan has successfully resolved disputes for taxpayers on a wide range of issues, including tax avoidance, the general anti-avoidance rule, permanent establishment, tax shelters, interest deductibility, SR&ED claims, charitable status, retirement compensation arrangements, directors’ liability, shareholder benefits and group tax appeals. He resolves tax disputes with the Canada Revenue Agency as well as provincial and other taxation authorities. Where tax disputes are not resolved at the administrative level, Stevan represents taxpayers at all levels of court. Stevan’s representative work includes:
- Retained by the Commission of Inquiry into Certain Allegations Respecting Business and Financial Dealings Between Karlheinz Schreiber and the Right Honourable Brian Mulroney, to advise the Commission on tax dispute resolution matters, including the CRA's voluntary disclosures program.
- Completed a voluntary disclosure on behalf of a multi-national corporation for taxes and interest payable in Canada resulting from carrying on business from a Canadian permanent establishment. All civil penalties were waived and the total potential exposure, including interest payable, was reduced substantially.
- Acted on behalf of two taxpayers appealing directors’ liability assessments totalling approximately $2.4 million. The Tax Court of Canada allowed the appeals, vacated the assessments and ordered the CRA to pay costs to the taxpayers fixed at $275,000, one of the highest cost awards ever in favour of taxpayers.
- Acted on behalf of a large group of taxpayers to advance representative cases before the Tax Court of Canada, the Federal Court of Appeal and the Supreme Court of Canada, dealing with the taxation of convertible hedge securities transactions.
- Obtained a rectification order to correct an international acquisition structure, involving the application of the subsection 88(1) so-called "bump rules," to avoid a substantial tax exposure.
- Obtained a rectification order to correct the mistaken treatment of a shareholder payment, to avoid a substantial tax exposure.
- Acted on behalf of registered charities and registered Canadian amateur athletic associations to resolve tax compliance issues.
- Acting on behalf of a large group of taxpayers in a limited partnership to advance two test cases before the Tax Court of Canada, dealing with the general anti-avoidance rule and pursuing a taxpayer relief application seeking to reduce the interest payable.
- Negotiated a settlement resulting in the CRA allowing in full, without a technical or financial audit, a SR&ED claim that had previously been disallowed on the basis it was late filed.
Stevan has written extensively and has been interviewed by national media on tax dispute resolution. He has also presented seminars on tax dispute resolution to CFOs, tax directors, general counsel and tax advisors and accounting professionals, including the ICAO Practitioners’ PD Conference and Federated Press. |
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