 Bennett Jones Jehad HaymourPartner • Vice Chair, Tax Litigation and Dispute Resolution Practice Calgary haymourj@bennettjones.com Education University of Calgary, BComm, 1986 University of Alberta, MBA, LLB, 1990 Bar Admissions Alberta, 1991 Overview Jehad Haymour has practised tax litigation for over 30 years, with an emphasis on tax disputes for large corporations. He has represented clients before the CRA, Tax Court of Canada, Federal Court of Appeal, and the Supreme Court of Canada. He advises Canadian and global clients on complex tax disputes and other matters including tax and financial reporting advice related to transactions, advice on resource taxation matters, obtaining income tax rulings, and advice on transfer pricing and other cross-border tax issues. Jehad is a recognized leader in tax litigation. He is ranked by Chambers Global, Chambers Canada, Lexpert, Best Lawyers Canada, Legal 500 Canada, and International Tax Review as a leading lawyer in the area. Jehad is a member of the Tax Court of Canada Judicial Advisory Committee and he is also a member of the Canadian Association of Petroleum Producers, Tax Committee, former President and Member of the Board of Directors of the Canadian Petroleum Tax Society and is an active member of Canadian tax and legal industry associations. He is a former member of the Tax Court Bench and Bar Committee. He regularly shares his insights and thought leadership through writing and presentations. Experience • 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. |