John A. Sorensen Associé Cochef, groupe Règlement de différends fiscaux

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Bureau principal :  Toronto

John A. Sorensen

John Sorensen is the Canadian co-leader of Gowling WLG’s Tax Dispute Resolution team, an integral part of the firm's Tax Group. He is also a member of the firm’s conflicts committee and the past leader of the firm’s national Tax Group. He has been ranked by the Best Lawyers in Canada, International Tax Review 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 and remission order applications.

John is past chair of the Ontario Bar Association Tax Section Executive. He has spoken and written on tax dispute resolution topics for the Tax Executives Institute, Canadian Tax Foundation's national and regional conferences, the Ontario Bar Association, the Canadian Association of Business Economics and the C.D. Howe Institute. John has lectured in the Osgoode Hall Law School JD and LL.M. (Tax) programs and also serves on the editorial boards of Thomson Reuters' Tax Litigation. John is also co-editor and contributing author to Taxation of Private Corporations and Their Shareholders, 5th ed. (forthcoming).

Carrière et Distinctions

Filtre chronologie
  • 2016

  • 2015

    • Classements et prix
      septembre 2015
      Best Lawyers in Canada 2016
    • Communauté
      juillet 2015
      Ontario Bar Association Tax Section Chair
  • 2014

    • Communauté
      juillet 2014
      Ontario Bar Association Tax Section Vice-Chair
  • 2012

    • Communauté
      juillet 2012
      Ontario Bar Association Tax Section Program Co-ordinator
  • 2011

    • Formation
      Osgoode Hall Law School, LLM (Tax)
  • 2007

    • Communauté
      octobre 2007
      Canadian Tax Foundation - Toronto YP Chair
  • 2005

    • Carrière
      octobre 2005
      Tax Court of Canada
    • Formation
      Osgoode Hall Law School, JD
  • 1996

    • Formation
      McGill University, M.Mus.
  • 1993

    • Formation
      St. Francis Xavier University, B.Mus.

Associations professionnelles

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

Mandats représentatifs

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: