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Kimura
  • Articling Student
On 10/20/2021 at 5:13 PM, Chambertin said:

It depends on if you're a planner or litigator. 

If a planner, tons. You can work for banks or big institutional clients, insurance, oil, basically your former clients. That is what Bob did.

For a litigator, there really isn't, other than moving to DOJ. There really isn't a role for a tax litigator that's not private firm or DOJ. If there is, tell me about it!

 

Trying to revive a conversation on exit opportunities for corporate tax lawyers. 

Was speaking with someone the other day and they mentioned the exit opportunities are somewhat limited in that most of the work is practiced in a firm environment. 

Are the opportunities to go in house as a tax lawyer as common as it would be for a corporate lawyer? If they are as common, how many years out do you need to be before those opportunities arise? 

Just trying to get a better grasp of the opportunities available outside of big law, because I very much enjoy tax, but don't want to feel trapped if life circumstances change. 

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Pantalaimon
  • Lawyer

I think most big companies have a tax group, so I don't see why they would be particularly limited. Most of the partners at my firm did some time in-house.

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On 8/19/2022 at 2:40 PM, Chambertin said:

Speaking of Finance Canada, they dropped this little nugget on August 9.

Modernizing and Strengthening the General Anti-Avoidance Rule

Recommendations include making a 'choice' an avoidance transaction, relieving the Minister of their burden to prove the object and spirit of the Act and extended the reassessment period for GAAR. 🤔

These were the tame options, I tend to think the GAAR is not working as intended because the SCC has refused to do the normative analysis that it asks for (which I am skeptical of solutions for).

Pretty excited to see my legislation in the FES (I held the pen on FHSA).

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2.001   (1)In this section:

"avoidance transaction" means a transaction

(a)that, but for this section, would result, directly or indirectly, in a tax benefit, or

(b)that is part of a series of transactions, which series, but for this section, would result, directly or indirectly, in a tax benefit,

but does not include a transaction that may reasonably be considered to have been undertaken or arranged primarily for bona fide purposes other than for the purpose of obtaining a tax benefit;

"tax benefit" means a reduction, avoidance or deferral of tax payable under this Act;

"transaction" includes an arrangement or event.

(2)For the purposes of this section, a series of transactions is deemed to include any related transactions completed in contemplation of the series.

(3)If a transaction is an avoidance transaction, the administrator may determine the tax consequences to a transferee or transferor in a manner that is reasonable in the circumstances in order to deny a tax benefit that, but for this section, would result, directly or indirectly, from that transaction or from a series of transactions that includes that transaction.

(4)The tax consequences to any person, after the application of this section, must be determined only through an assessment under section 18.

 

 

🙂 just get rid of misuse or abuse entirely....

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Chambertin
  • Lawyer
On 11/3/2022 at 10:27 AM, Kimura said:

Trying to revive a conversation on exit opportunities for corporate tax lawyers. 

Was speaking with someone the other day and they mentioned the exit opportunities are somewhat limited in that most of the work is practiced in a firm environment. 

Are the opportunities to go in house as a tax lawyer as common as it would be for a corporate lawyer? If they are as common, how many years out do you need to be before those opportunities arise? 

Just trying to get a better grasp of the opportunities available outside of big law, because I very much enjoy tax, but don't want to feel trapped if life circumstances change. 

I don't know if it's as true for corporate as in-house, but there are certainly plenty of tax positions in-house. It would also depend on how specialized your skill set is, that could work for or against. 

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