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Stevan Novoselac
Partner, Tax Dispute Resolution

Speaks: English

Year of Call: 1990 - Ontario

Primary Office: Toronto

Stevan Novoselac

Stevan Novoselac is the Canadian leader of Gowling WLG's Tax Dispute Resolution team, an integral part of the firm's Tax Group. With more than 25 years' experience, he is listed as a Tax Controversy Leader in Canada for 2013, 2014 and 2015 by International Tax Review.

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 frequently offers his expertise to national media outlets on matters related to tax dispute resolution and has contributed op-ed pieces to The Globe & Mail. Some recent examples are as follows:

He has also presented seminars on tax dispute resolution to CFOs, tax directors, general counsel and tax advisers and accounting professionals, including the ICAO Practitioners’ PD Conference. In May 2016, he participated in a Gowling WLG-hosted webinar entitled International Tax Crackdown: What you need to know about the new reality

Stevan is also active in the community, serving on the boards of directors of two charities and one not-for-profit corporation.


Stevan helps taxpayers across Canada resolve all kinds of tax disputes.

October2015

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

October2014

International Tax Review - Tax Controversy Leaders 2014

September2013

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

1990

Year of Call, Ontario

1988

Osgoode Hall Law School, LLB

Featured insights & resources

Non-party donative program promoter ordered to pay costs in tax court appeal

Stevan Novoselac

Article August 23, 2016

Supreme Court of Canada upholds solicitor-client privilege in tax administration and enforcement

Jeff Beedell, Stevan Novoselac

Article June 6, 2016

Urgent advisory: Commence voluntary disclosures before the end of 2015

John A. Sorensen, Stevan Novoselac

Article December 1, 2015

Tension and trends in tax-driven rectification: Graymar Equipment (2008) Inc and Fairmont Hotels Inc

David P. Stevens, Stevan Novoselac

Article July 1, 2015

Why you should voluntarily disclose your offshore investments

Stevan Novoselac

Article July 1, 2015

Top ten CRA audit flags

John A. Sorensen, Stevan Novoselac

Article December 1, 2013

Memberships

Career & Recognition

2015

October 2015

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

2014

October 2014

International Tax Review - Tax Controversy Leaders 2014

2013

September 2013

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

1990

1990

Year of Call, Ontario

1988

1988

Osgoode Hall Law School, LLB

1985

1985

McMaster University, BComm.

Stevan Novoselac
Profile highlights

#
Stevan Novoselac

Stevan Novoselac is the Canadian leader of Gowling WLG's Tax Dispute Resolution team, an i...

Stevan Novoselac
Featured insights & resources

Non-party donative program promoter ordered to pay costs in tax court appeal

Stevan Novoselac

Article August 23, 2016

Memberships

Insights & Resources

Non-party donative program promoter ordered to pay costs in tax court appeal

Stevan Novoselac

Article August 23, 2016

Supreme Court of Canada upholds solicitor-client privilege in tax administration and enforcement

Jeff Beedell, Stevan Novoselac

Article June 6, 2016

Will the CRA change its enforcement in wake of Panama Papers?

Stevan Novoselac

Article April 7, 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

Why you should voluntarily disclose your offshore investments

Stevan Novoselac

Article July 1, 2015

Tension and trends in tax-driven rectification: Graymar Equipment (2008) Inc and Fairmont Hotels Inc

David P. Stevens, Stevan Novoselac

Article July 1, 2015

Top ten CRA audit flags

John A. Sorensen, Stevan Novoselac

Article December 1, 2013

Stevan Novoselac
Profile highlights

#
Stevan Novoselac

Stevan Novoselac is the Canadian leader of Gowling WLG's Tax Dispute Resolution team, an i...

Insights & Resources

Client Work

Stevan’s representative work includes:

  • Acted for international Internet electronic commerce service providers, to successfully resolve novel and precedent-setting GST/HST disputes, including whether a non-resident electronic commerce enterprise provided taxable services and was carrying on business in Canada.
  • Successfully resolved withholding tax reassessments on payments from a Canadian broadcasting company to its wholly-owned foreign parent, involving high-level inter-related negotiations with CRA audit and appeals, the Department of Justice, the Office of the Taxpayers’ Ombudsman and the Department of Finance, in conjunction with an appeal to the Tax Court of Canada.
  • 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 of its kind 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.
  • Acted on behalf of registered charities and registered Canadian amateur athletic associations to resolve tax compliance issues.
  • Acted 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 pursued 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 Novoselac
Profile highlights

#
Stevan Novoselac

Stevan Novoselac is the Canadian leader of Gowling WLG's Tax Dispute Resolution team, an i...

Stevan Novoselac
Featured insights & resources

Non-party donative program promoter ordered to pay costs in tax court appeal

Stevan Novoselac

Article August 23, 2016

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