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John A. Sorensen
Partner

Primary Office: Toronto

John A. Sorensen

John Sorensen resolves tax disputes and is ranked by Best Lawyers in Canada 2016 in the area of taxation law. He has also regularly been ranked as one of the leading tax controversy professionals in Canada by the International Tax Review.

A partner based in Gowling WLG's Toronto office, John provides prudent advice and expeditious, cost-effective solutions to tax problems. He has wide-ranging experience dealing with substantive tax issues, including the thin capitalization rules, interest deductibility, SR&ED claims, partnership allocations, shareholder benefits, the general anti-avoidance rule, the foreign accrual property income rules, proceeds of crime, inventory valuation and GST/HST matters. He also acts on behalf of tax practitioners who are alleged to have provided mistaken tax advice.

John has appeared before the Tax Court of Canada, the Federal Court, the Federal Court of Appeal and the Ontario Superior Court of Justice. He has also helped clients successfully resolve tax problems through appeals to the Canada Revenue Agency and provincial tax authorities, and through voluntary disclosures, taxpayer relief applications and remission order applications. 

John is chair of the Ontario Bar Association Tax Section Executive. He has spoken and/or written on tax dispute resolution topics for the Canadian Tax Foundation's national and regional conferences, the Ontario Bar Association and the C.D. Howe Institute. He has also been quoted on tax topics in the national and international press. 

Additionally, John is a regular contributor to the Tax Dispute Resolution Group’s quarterly newsletter, and is actively involved in managing the group’s LinkedIn page.


October2015

International Tax Review — Tax Controversy Leaders 2015 and Indirect Tax Leaders 2015

September2015

Best Lawyers in Canada 2016

September2015

Tax Controversy Leader - International Tax Review

September2015

The Best Lawyers in Canada 2016

July2015

Ontario Bar Association Tax Section Chair

Featured insights & resources

Alternative arguments in support of tax assessments

John A. Sorensen

Article August 23, 2016

Gross negligence penalties upheld against wilfully blind sophisticated taxpayer

John A. Sorensen

Article August 23, 2016

Dissolved corporation lacks standing in tax court

John A. Sorensen

Article May 31, 2016

Contempt of court — Facing the music

John A. Sorensen

Article March 30, 2016

Urgent advisory: Commence voluntary disclosures before the end of 2015

John A. Sorensen, Stevan Novoselac

Article December 1, 2015

Rescission remedy takes a step sideways in JAFT

John A. Sorensen

Article September 1, 2015

Tax preparer penalties not criminal sanction: The SCC judgment in Guindon

John A. Sorensen

Article August 1, 2015

Memberships

Career & Recognition

2015

October 2015

International Tax Review — Tax Controversy Leaders 2015 and Indirect Tax Leaders 2015

2015

September 2015

Best Lawyers in Canada 2016

2015

September 2015

Tax Controversy Leader - International Tax Review

2015

September 2015

The Best Lawyers in Canada 2016

2015

July 2015

Ontario Bar Association Tax Section Chair

2014

October 2014

International Tax Review - Tax Controversy Leaders 2014

2014

September 2014

Tax Controversy Leader - International Tax Review

2014

July 2014

Ontario Bar Association Tax Section Vice-Chair

July 2014 - July 2015

2013

September 2013

International Tax Review ’s Tax Controversy & Indirect Tax Leaders guides 2013

2013

September 2013

Tax Controversy Leader - International Tax Review

2012

July 2012

Ontario Bar Association Tax Section Program Co-ordinator

July 2012 - July 2014

2007

October 2007

Canadian Tax Foundation - Toronto YP Chair

October 2007 - September 2013

2005

October 2005

Tax Court of Canada

October 2005 - September 2006

McGill University, M.Mus.

Osgoode Hall Law School, JD

Osgoode Hall Law School, LLM (Tax)

St. Francis Xavier University, B.Mus.

John Sorensen
Profile highlights

#
John Sorensen

John Sorensen resolves tax disputes and is ranked by Best Lawyers in Canada 2016...

John Sorensen
Featured insights & resources

Alternative arguments in support of tax assessments

John A. Sorensen

Article August 23, 2016

Memberships

Insights & Resources

Alternative arguments in support of tax assessments

John A. Sorensen

Article August 23, 2016

Gross negligence penalties upheld against wilfully blind sophisticated taxpayer

John A. Sorensen

Article August 23, 2016

“Money for nothing” scheme lands de-taxer in federal penitentiary for six years

John A. Sorensen

Article August 23, 2016

Dissolved corporation lacks standing in tax court

John A. Sorensen

Article May 31, 2016

Contempt of court — Facing the music

John A. Sorensen

Article March 30, 2016

Federal Budget 2016 — Incremental, not fundamental tax changes

Multiple Authors

Article March 23, 2016

Urgent advisory: Commence voluntary disclosures before the end of 2015

John A. Sorensen, Stevan Novoselac

Article December 1, 2015

Rescission remedy takes a step sideways in JAFT

John A. Sorensen

Article September 1, 2015

Tax preparer penalties not criminal sanction: The SCC judgment in Guindon

John A. Sorensen

Article August 1, 2015

Forced audit disclosure of uncertain tax positions

John A. Sorensen

Article July 1, 2015

Top ten CRA audit flags

John A. Sorensen, Stevan Novoselac

Article December 1, 2013

John Sorensen
Profile highlights

#
John Sorensen

John Sorensen resolves tax disputes and is ranked by Best Lawyers in Canada 2016...

Insights & Resources

EXTERNAL PUBLICATIONS &
PAST SPEAKING ENGAGEMENTS

  • The Minister Still Can’t Appeal Her Own Assessment, Canadian Tax Journal, Vol. 62, No. 4, February 2015
  • CRA Administrative Position – Late Reassessments, CTF Highlights, Vol. 22, No. 11, November 2014
  • OBA Tax Section CLE Session: Ethics and Professionalism – Backdating, October 20, 2014
  • Parol Evidence in Tax Litigation, CTF Highlights, Vol. 22, No. 10, October 2014
  • Taxpayers Cannot Avoid Late-Filing Penalty by Filing Nil Return, OBA Tax Section Newsletter, September 19, 2014
  • Time to Object Extended, CTF Canadian Tax Highlights, Vol. 22, No. 8, August 2014
  • The Minister Still Can’t Appeal Her Own Assessment (forthcoming)
  • Access to Tax Policy Information Denied, CTF Canadian Tax Highlights, Vol. 22, No. 6, June 2014
  • New CRA Directors’ Liability IC, CTF Canadian Tax Highlights, Vol. 22, No. 5, May 2014
  • The Cost of Folly or a Folly of Costs, Tax Topics, No. 2202, May 22, 2014 
  • 2013 Tax Court Bench and Bar Committee Highlights, Ontario Bar Association Taxation Law Section Newsletter, April 2014
  • The TCC Upholds Penalties – Novel Arguments Fail to Save the Day, Ontario Bar Association Taxation Law Section Newsletter, April 2014
  • The Settlement Cone of Silence, Tax Litigation Journal, Federated Press Tax Litigation Journal, Volume 19, No. 2, April 2014
  • The Implied Undertaking Rule Saves the Day from the CRA, Canadian Tax Highlights, April 2014
  • New Audit Enquiry Guidelines:  A Closer Look at the Negotiations, Law Times, February 2014
  • Non-Criminal Penalties Under the Income Tax Act, Canadian Tax Foundation, Ottawa, February 6, 2014
  • Wilful Blindness Supports Assessment of Gross Negligence Penalties, Canadian Tax Foundation, Canadian Tax Highlights, Vol. 22, No. 2, February 2014
  • Tax Court of Canada 2013 Canadian Tax Foundation Update, OBA Tax Section Newsletter, January 2014
  • Reverse Auditing: Accessing the CRA’s Records Pertaining to Taxpayers, OBA Tax Section presentation and paper, November 2013
  • Guindon, Third Party Penalties Revisited, CTF Journal, (2013) 61:4
  • The CRA’s New and Aggressive Tax Enforcement Powers and How Taxpayers Can Protect Themselves, Federated Press International Tax Planning Journal, Vol. 18, No. 4, 1270 to 1274, October 2013
  • Protecting Tax Accrual Workpapers – Revisited … Again …, Carswell BorderCrossings Newsletter, Vol. 6, no. 2, October 2013
  • Non-Criminal Penalties under the Income Tax Act, 2013 Ontario Regional Tax Conference, Canadian Tax Foundation, Toronto, ON, October 28 and 29, 2013
  • GAARguments in the Tax Court of Canada: Crown Must Disclose Policy Supporting GAAR Assessments, Canadian Tax Journal, Volume 51, No. 2, August 2013
  • A Comprehensive Discussion of Penalties – 2013 Prairie Provinces Tax Conference, Canadian Tax Foundation, Edmonton, AB, May 27, 2013
  • Policies, Penalties and Tax Dispute Resolution – Ontario Bar Association, London, Ontario, May 2, 2013
  • Canadian Non-Resident Trust Rules – Case Studies, Carswell BorderCrossings Newsletter, Vol. 6, No. 1, April 2013
  • Waiver of Rights Fatal to Tax Appeal, Ontario Bar Association, Taxation Law Section Newsletter, Vol. 23, No. 2, March 2013
  • Audit Inquiry Letters and FIN 48 Advice: The Tip of the Iceberg, Ontario Bar Association presentation and webcast, December 2012
  • Voluntary Disclosure and Taxpayer Relief – Canadian Tax Foundation presentation, September 2012
  • Executor Liability: Dealing with Historic Tax Non-Compliance in Canada and the United States, Carswell BorderCrossings Newsletter, Vol. 5, No. 2, July 2012
  • CTF – TCC Update, OBA Tax Section Newsletter Vol. 22, No. 2, June 2012
  • The Federal Court of Appeal Settles Some Settlement Questions?, Canadian Tax Foundation Journal, Volume 60, No. 1, 2012
  • To Fight or Not to Fight – To Pay or Not to Pay: Factors to Consider When Dealing With Tax Assessments, CA Magazine, May 2012
  • Director’s Liability for GST – No Requirement for the Minister to Behave Reasonably, Canadian Tax Highlights, Vol. 20, No. 3, March 2012
  • Lack of Disclosure Fatal to Government’s Case, Canadian Tax Focus, Vol. 2, No. 1, February 2012
  • International Tax Administration and Enforcement: Extended Reassessment Period for Transactions with Non-Arm's Length Non-Residents, Ontario Bar Association Taxation Newsletter, Vol. 21, No. 2, April 2011
  • TCC Settlements, Canadian Tax Highlights, Vol. 19, No. 3, March 2011
  • If There's Smoke, Is There Fire?, CA Magazine, March 2011
  • The Proposed Reportable Transactions Regime - Where There is Smoke There May be Fire, Taxation Law @ Gowlings Seminars in Toronto, Hamilton and Waterloo, November 2010 and Federated Press, May 2011
  • Move Quickly on Voluntary Tax Disclosure, Law Times, November 8, 2010
  • Managing the Flow of Information to the Canada Revenue Agency, May 2009, Taxation Law @ Gowlings Seminars in Toronto, Waterloo and Hamilton
  • Aim Funds Management Inc. v. Aim Trimark Corporate Class Inc., Is the Minister a Proper Party to a Rectification Application? Canadian Tax Journal, 2009, Vol. 57, No. 4
  • Lang v. M.N.R., The New Handbook for Determining a Worker's Status as an Employee or Independent Contractor, Canadian Tax Journal, 2008, Vol. 56, No. 1
  • Prevost Carr v. M.N.R., case comment, Taxand Quarterly, No. 11, 2008
  • Alternative Basis for Reassessments and Waivers, Ontario Bar Association Taxation Newsletter, Vol. 18, No. 1, 2007
  • The Use of Special Purpose Trusts, Proceedings of the 59th Annual Canadian Tax Foundation Conference, 2007 CR p.35:1
  • The Use of Technical Notes in Statutory Interpretation, Tax Litigation, Vol. XIV, No. 1, 2006, Federated Press

Client Work

Industry Canada blocks US$36.8 billion hostile takeover bid by BHP Billiton Group of Potash Corporation of Saskatchewan Inc.

Client Work March 11, 2010

John has served as counsel in various reported decisions, including:

John Sorensen
Profile highlights

#
John Sorensen

John Sorensen resolves tax disputes and is ranked by Best Lawyers in Canada 2016...

John Sorensen
Featured insights & resources

Alternative arguments in support of tax assessments

John A. Sorensen

Article August 23, 2016

Follow John on Twitter @JohnASorensen

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