Jehad Haymour
Partner • Vice Chair, Tax Litigation and Dispute Resolution Practice

Outline
Overview
Client Work
Shopify in its successful opposition in the Federal Court of two CRA applications for Shopify to divulge business information about its merchants
BP Canada Energy Group ULC, as tax counsel in the sale of its 50% stake in the Sunrise oil sands project in northern Alberta to Cenovus Energy Inc.
Providing tax structuring and other tax advice to clients that include large resource-based organizations and other organizations on various tax matters, including the tax treatment to be afforded to aspects of proposed transactions and expenditures incurred under the Income Tax Act (Canada).
Advising on transfer pricing matters including disputes related to: Canadian deductibility of indemnity payments made in respect of an international sale of assets; Canadian deductibility of cross-border pro-rata feasibility study costs; Canadian deductibility of losses on financial derivatives; Whether a US corporation had an permanent establishment in Canada by virtue of the operations of its Canadian subsidiary.
Assisting clients in obtaining CRA advance tax rulings and technical interpretations on resource taxation and other taxation issues.
Advising taxpayers in ongoing disputes and dealings with the Canada Revenue Agency and Alberta Revenue and in tax litigation matters before the Tax Court of Canada, Federal Court of Appeal and the Supreme Court of Canada. Reported tax litigation includes: Petro-Canada v. R., 2003 DTC 94 (TCC); The Queen v. McLarty, 2008 SCC 26; Collins v. The Queen, 2010 FCA 12; Global Equity Fund Ltd. v. The Queen, 2011 TCC 507, rev'd at 2012 FCA 272, leave to appeal to SCC denied; McLarty v. R., 2014 TCC 30; Olympia Trust Company v. R., 2014 TCC 372, 2015 FCA 279.
Recognitions & Awards
Chambers Canada
Recognized, Tax: Litigation
Chambers Global
Band 2, Tax Litigation
Legal 500 Canada
Leading Lawyer, Tax
Canadian Legal Lexpert Directory
Consistently Recommended, Corporate Tax; Litigation – Corporate Tax
Lexpert Special Edition—Canada's Leading Finance and M&A Lawyers
Recognized as a leading Finance and M&A lawyer
Lexpert Special Edition: Litigation
Recognized as one of Canada's leading lawyers in litigation
Related Services
Education & Bar Admissions
Education
- University of Calgary, BComm, 1986
- University of Alberta, MBA, LLB, 1990
Bar Admissions
- Alberta, 1991