Stevan Novoselac Associé Cochef, groupe Règlement de différends fiscaux

Parle :  Anglais

Year of Call: 1990 - Ontario

Téléphone principal : +1 416-862-3630

Fax : +1 416-862-7661

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Bureau principal :  Toronto

Stevan Novoselac

Stevan Novoselac is the Canadian co-leader of Gowling WLG's Tax Dispute Resolution team, an integral part of the firm's Tax Group. With more than 30 years' experience, he has been listed as a Tax Controversy Leader in Canada for each of the last nine years by World Tax, in association with the International Tax Review, and has been recognized as a leader in his field by Best Lawyers in Canada in 2020 and 2021.

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 and other publications. 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.

Carrière et Distinctions

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Associations professionnelles

  • Canadian Bar Association
  • Canadian Tax Foundation
  • Ontario Bar Association
  • Toronto Lawyers Association

Mandats représentatifs

Stevan’s representative work includes:

  • Obtained a rectification order to avoid an unintended U.S. accounting loss, involving the interplay amongst international tax-driven transactions, Canadian tax, U.S. tax, U.S. accounting rules and the restructuring of dozens of cross-border hybrid entities.
  • 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.