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John A. Sorensen Partner Co-Leader, Tax Dispute Resolution / Co-Department Head, Toronto Business Law Department

Speaks:  English

Year of Call: 2006 - Ontario

Primary phone: +1 416-369-7226

Fax: +1 416-862-7661

Email: john.sorensen@gowlingwlg.com

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Primary office:  Toronto

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John A. Sorensen

John Sorensen is co-head of the Business Law Department in the Toronto office, a member of the Toronto office management committee, and co-leader of the Firm's Tax Dispute Resolution Group. He has been ranked by Chambers Canada, Best Lawyers in Canada, International Tax Review, Lexpert Special Edition: Litigation, and the Canadian Legal Lexpert Directory.

A partner based in Gowling WLG's Toronto office, John provides prudent advice and expeditious, cost-effective solutions to tax problems. He has extensive experience resolving income tax and GST/HST disputes at the audit and appeal stages, as well as before the courts. His practice also includes voluntary disclosure, taxpayer relief, rectification, rescission, and remission order applications.

John frequently speaks and writes on tax dispute resolution topics, including for the Canadian Tax Foundation, Tax Executives Institute and the International Fiscal Association. He is a co-editor and contributing author to Taxation of Private Corporations and Their Shareholders, 5th ed. (CTF, 2020) and Tax Disputes in Canada: the Path Forward (CTF, 2022). John is on the board of governors of the Canadian Tax Foundation, the chair of the Advocates' Society tax litigation section, and a member of the board of directors of the Advocates' Society. He is also a faculty member in the Osgoode Hall LL.M. (tax) program.

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Career & Recognition

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Memberships

  • Canadian Bar Association
  • Canadian Tax Foundation
  • International Fiscal Association
  • The Advocates' Society

Insights & Resources

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26 June 2023 Budget 2023 proposed GAAR amendments: Rewriting the rules – the ultimate game-changer
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16 June 2023 2023 Tax Dispute Resolution Quarterly Update | Session 2 CLE/CPD:30 minutes
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29 March 2023 Federal Budget 2023: Modest tax measures emphasizing incentives for a greener economy

Featured news

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28 September 2023 Chambers Canada 2024 recognizes 79 Gowling WLG lawyers across 41 practice areas
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24 August 2023 The Best Lawyers in Canada™ 2024 names Gowling WLG "Law Firm of the Year" in Advertising and Marketing Law, recognizes 243 lawyers
02 March 2023 2023 Canadian Legal Lexpert Directory recognizes 211 Gowling WLG lawyers
  • Editor, "Tax Disputes in Canada: The Path Forward," Canadian Tax Foundation Publication, December 2022
  • No Waiver of Notice of Objection Filing Requirements, CTF Highlights, Vol. 26, No. 2, February 2018
  • Backdating of Dividends, Tax Topics, January 11, 2018, No. 2392
  • Standard of Proof and Prima Facie Case, CTF Highlights, Vol. 25, No. 11, November 2017
  • Potpourri of Administration and Enforcement Issues, CTF 69th Annual National Conference (Toronto), November 20, 2017
  • Successful Motion to Strike - Mont Bruno, CTF Highlights, Vol. 25, No. 9, September 2017
  • Proposed Changes to the Voluntary Disclosures Program, Thomson Reuters Tax Litigation Journal Vol. XX, No. 4
  • Failed Motion to Seal Court File, CTF Highlights, Vol. 25, No. 8, August 2017
  • Discoverability of Claims Against Tax Advisors, CTF Highlights, Vol. 25, No. 6, June 2017
  • New Argument Raised Too Late, CTF Highlights, May 2017
  • Cautionary Tales for Counsel When Settling Tax Appeal (Granofsky and Davies), CTF Journal, (2017) 65:1
  • Trial Must Decide Status of Foreign Rectifications, CTF Highlights, Vol. 25, No. 4, April 2017
  • Credibility in an Assessment Mailing Case, CTF Highlights, Vol. 25, No. 1, January 2017
  • Judicial Review and MAP, CTF Highlights, Vol. 24, No. 12, December 2016
  • Anatomy of a Tax Assessment and Proposed Amendments to ss. 152(9), Canadian Institute Tax Controversies and Disputes Newsletter, Vol. 1, No. 2, Fall 2016
  • Privilege Affirmed, but What's Next After Chambre des notaires du Québec and Thompson?, CTF Journal, Vol. 64, No. 3, 2016
  • TCC Discovery of Non-Party, CTF Highlights, Vol. 24, No. 6, June 2016
  • Superior Plus Corp. - Motion Seeking Policy Information in GAAR Case, Canadian Tax Journal, Vol. 64, No. 1, 2016
  • Dissolved Corporation Lacks Standing in Tax Court, OBA Tax Section Newsletter, May 2016
  • Discretion to Waive Timely Objection, CTF Highlights, Vol. 24, No. 5, May 2016
  • Jeopardy Order Overturned, CTF Highlights, Vol. 24, No. 2, Feb 2016
  • Comprehensive Review of Interest and Penalty Relief Under the Income Tax Act, Proceedings of the 67th Annual Tax Conference, Canadian Tax Foundation, 2015 Conference Report, 41: 1 - 49
  • T1 Adjustments Waive Reassessment Period, Canadian Tax Highlights, Vol. 23, No. 9, September 2015
  • 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
  • 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

Representative Work

John's recent client work has included:

  • Resolving numerous Tax Court of Canada appeals on favourable bases without requiring full hearings before the Court, including income tax matters concerning earn-outs, shareholder benefits, scientific research and experimental development tax credits, partnership allocations, real property valuations, non-compete payments, civil penalties and the thin capitalization rules, as well as GST/HST matters
  • Obtaining numerous rectification orders to correct mistaken transactions, from large-scale corporate restructurings to estate freezes, including in the context of representing counsel from other firms who allegedly provided mistaken advice
  • Completing voluntary disclosures for numerous multinationals, Canadian corporations, charities and individuals with previously undisclosed income and assets and unfiled tax and information returns, thus avoiding the imposition of significant civil penalties and avoiding potential prosecution for tax evasion
  • Assisting numerous disadvantaged individuals on a pro bono basis, saving them from bankruptcy arising from mistaken CRA assessments

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