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Stevan Novoselac is a partner with Gowlings’ business law department and heads up the tax dispute resolution practice at the Toronto office as part of the Firm's Tax National Practice Group.
Stevan represents taxpayers across Canada and his practice is devoted exclusively to resolving all types of tax disputes, including voluntary disclosures, requirements for information, audits, objections, appeals, collections issues, fairness 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, tax shelters, interest deductibility, SR&ED claims, 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 and potential criminal prosecution 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, the highest cost award ever in favour of taxpayers.
- Acting 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 the mistaken treatment of a shareholder payment and avoid a substantial tax exposure.
- Acting 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 fairness 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.
- Negotiated a settlement with the CRA on behalf of an individual with a substantial amount of alleged unreported income, substantially reducing the potential exposure.
- Retained after a notice of appeal was filed and negotiated a highly favourable settlement before the reply to the notice of appeal was filed, thereby successfully avoiding the entire Tax Court of Canada process.
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. |
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