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income, gains or losses from non-Canadian (offshore) assets.

gains and losses from non-traditional asset classes such as derivatives and crypto-currencies.

scientific research and experimental development (SRED) expense challenges.

tax loss planning including loss consolidation and non-acquisition of control transactions.

His is experienced in CRA audit management and in defending against CRA challenges to: He also represents high net worth individuals who have been targeted by the CRA. He zealously guards the interests of his clients to obtain the best result possible.ĭavid’s clients are comprised largely of corporate taxpayers. He becomes involved when the CRA tries to insist that his clients pay more than required by law.ĭavid is one of the top creative tax problem solvers in the country.

The Canada Revenue Agency (CRA) can only collect amounts to which it is legally entitled, and no more. The above quote reflects David’s philosophy. If they succeed, then, however unappreciative the or fellow taxpayers may be of their ingenuity, they cannot be compelled to pay an increased tax.” David is a tax litigator who specializes in challenging adverse tax reassessments issued by the Canada Revenue Agency.Īn English judge once wrote that “every person is entitled to order his (or her) affairs so that the tax is less than it otherwise would be.