Christopher Slade

Partner Admitted to the Ontario Bar: 2009
  • Toronto

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  • Bio
  • Awards & Recognition
  • Professional Involvement
  • Representative Matters
  • Selected Speaking Engagements
  • Selected Publications
  • Insights
  • Education

Chris is highly regarded in domestic and international tax controversy and litigation. He is recognized by Chambers and Partners as a leading lawyer in the area of Tax Litigation, and is praised for being “extremely thorough and prepared” and “extremely responsible and very calm in his approach to clients’ situations.” Additionally, Chris is featured in the Canadian Legal Lexpert Directory as a top lawyer in Corporate Tax Litigation and has been included since 2019 in the International Tax Review’s World Tax Guide for his expertise in Tax Controversy. Chris’s strategic approach positions clients for effective negotiation with tax authorities and avoids unnecessary litigation. He has an exceptional track record, having successfully resolved the majority of his cases by consent judgment or at the administrative appeals level.

Chris is a member of the firm’s Tax and Tax Controversy/Tax Litigation Groups. He has represented a wide array of clients, including multinational corporations, financial institutions, private equity firms, pension funds and ultra high net worth individuals. Chris routinely handles high-value and complex cases, demonstrating broad expertise across the spectrum of tax controversy issues including the treatment of M&A deal costs, rules limiting the use of losses, transfer pricing, non-resident withholding tax, the General Anti-Avoidance Rule, income characterization, large group appeals relating to employee benefits and RRSP trusts,  and issues involving Canada’s goods and services tax/harmonized sales tax (GST/HST).

In addition to his expertise in tax litigation, Chris advises clients throughout the audit process. His practice includes the remediation of tax compliance errors, making disclosures under the Voluntary Disclosures Program, obtaining interest and penalty relief and securing other discretionary remedies. Chris is adept at challenging collection action and other administrative measures taken by tax authorities, particularly in the cross-border context. He has extensive experience resolving administrative disputes with the Canada Revenue Agency, and has acted on leading cases involving cross-border audits, foreign-based information requirements, compliance order proceedings, the Advance Pricing Agreement program and disputes relating to the Mutual Agreement Procedure in Canada’s income tax treaties. Chris also collaborates regularly with other members of the Tax Group to assist clients with transactional and tax advisory matters and has been engaged to provide expert tax opinion evidence in commercial arbitration proceedings.

Chris has made significant contributions to the field of tax law through his published articles on a variety of tax issues in professional legal journals, and he is currently co-author of the Chambers Tax Controversy Global Practice Guide (Canada Chapter). Chris has also presented at numerous conferences and events for tax executives and practitioners in Canada and internationally.

Early in his legal career, Chris completed a judicial clerkship at the Tax Court of Canada. Prior to joining Aird & Berlis, Chris was a senior partner at a national law firm affiliated with one of the Big 4 accounting firms, where he co-led the affiliated firm’s tax litigation practice in Toronto.

Awards & Recognition

  • Recognized in The Canadian Legal Lexpert Directory as a leading lawyer in the area of Litigation - Corporate Tax
  • Recognized by ITR World Tax (Canada) as a Highly Regarded practitioner in Tax Controversy
  • Recognized by Chambers Canada in the area of Tax Litigation
  • Osgood Society Prize, 2008
  • Dean’s Silver Scholar Award, Queen’s University, 2008
  • J.S.D. Tory Writing Award, Queen’s University, 2008
  • Sabbath Prize in Corporate Taxation, Queen’s University, 2008
  • Fasken Martineau LLP Prize in Civil Procedure, Queen’s University, 2008
  • Second Place Oralist and team prize for best factums, Canadian Corporate/Securities Law Moot, 2007
  • William S. O’Hara Prize in Criminal Law, Queen’s University, 2006
  • Lang Michener Award in Contracts, Queen’s University, 2006

Professional Involvement

Memberships

  • Canadian Tax Foundation
  • The Advocates’ Society
  • American Bar Association

Representative Matters

  • Tax Court appeal relating to the treatment of M&A deal costs and entitlement to claim a capital loss of approximately $1.4 billion for a Fortune 100 automotive company.
  • Tax Court appeal of assessments totalling approximately $140 million in relation to a cross-border distribution for a Fortune 500 life sciences company (successfully resolved on consent).
  • Tax Court appeal of an assessment in relation to the distribution of capital property held in trust and the alleged application of s. 107(4.1) of the Income Tax Act (successfully resolved on consent).
  • Tax dispute regarding entitlement to GST/HST input tax credits in the context of a reverse invoicing arrangement for a global production and event management company (successfully resolved at the objection stage).
  • Tax advice for a large privately-owned renewable energy company regarding the character of gains in excess of $450 million from the disposition of certain partnership interests. 
  • Tax dispute regarding the deductibility of losses following an acquisition of control for a pharmaceutical distribution company (successfully resolved at the audit stage).
  • Represented a multinational Canadian bank in a dispute involving refunds claimed under the International Business Activity Act of British Columbia.
  • Tax advice for a public multinational consumer goods company regarding whether a divestiture would be considered part of the same “series of transactions” as an earlier spin-off transaction.
  • Tax Court appeal regarding the tax consequences of an intellectual property licensing arrangement for a leading industrial manufacturing company (successfully resolved on consent).
  • Tax Court appeal regarding liability for minimum tax for a trust affiliated with a large construction union (successfully resolved on consent).
  • Federal Court judicial review application challenging a CRA requirement to provide information and documents for a high-net-worth non-resident of Canada (resolved on consent after CRA withdrew the requirement).
  • Tax dispute involving housing allowances paid to approximately 1,500 Canadian employees of a multinational consulting company (successfully resolved at the objection stage).
  • Tax dispute regarding the character of periodic payments under a $200 million cross-currency interest rate swap for a major insurance company (successfully resolved at the objection stage).

Selected Speaking Engagements

Panellist, 14th Annual IBA Finance & Capital Markets Tax Conference (Tax Litigation) (January 2025, London, UK). 

Panellist, 16th Annual Tax Controversy Forum, New York University (Think Globally: International Tax Enforcement and Disputes) (June 2024, New York, NY).

Panellist, 13th Annual London Finance and Capital Markets Conference (The Rise of Tax Litigation) (January 2024, London, UK).

Presenter, Canadian Tax Foundation 2023 Ontario Tax Conference (Tax Administration Issues) (October 2023, Toronto).

Discussion Co-Leader, 2023 Cambridge Forum on International Tax & Disputes (You’ve Got a Friend – Leveraging Relationships with Treaty Partners) (May 2023, Cascais, Portugal).

Presenter, U.S. Tax Court’s Inn of Court (Resolving Tax Disputes in Canada: Overview of the Administrative Appeals Process) (March 2023).

Moot Court Judge, Donald G. H. Bowman National Tax Moot (March 2023, Toronto).

Panellist, 12th Annual London Finance and Capital Markets Conference (Tax Litigation panel) (January 2023, London, UK).

Moot Court Judge, Donald G. H. Bowman National Tax Moot (March 2022, Toronto).

Presenter, Deloitte Global Tax Conference – Americas (Tax Planning and Managing Tax Controversy in a Shifting Canadian Economy) (March 2021, Toronto).

Presenter, Deloitte Corporate Tax Conference (Hot Topics in Dealing with the CRA) (July 2018, Toronto).

Presenter, Deloitte Investment Management Tax Seminar (Selected Issues in Tax Controversy) (October 2017, Toronto). 

Moot Court Judge, Donald G. H. Bowman National Tax Moot (March 2017, Toronto). 

Presenter, 16th Managing Tax Audits & Investigations Course by Federated Press (Assessments, Objections and the Appeals Process) (June 2013, Toronto).

Selected Publications

Co-Author, “Selected Issues in Tax Administration," 2023 Ontario Tax Conference (Toronto: Canadian Tax Foundation, 2023).

Co-Author, "Chambers Tax Controversy 2023 Global Practice Guide (Canada Chapter)," May 2023.

Co-Author, "Chambers Tax Controversy 2023 Trends and Developments (Canada Chapter)," May 2023.

Co-Author, "Solicitor-Client Privilege: A Refresher," Tax Profile (Wolters Kluwer), March 2023. 

Co-Author, "Equitable Remedies in the Tax Context after Collins Family Trust," Tax Profile (Wolters Kluwer), August 2022. 

Author, “The Federal Court of Appeal’s Decision in BP Canada Energy: New Limits on the Minister’s Power to Compel Production?” Tax Litigation (2017) Volume XX, No. 4, 2-7 (Toronto: Federated Press).

Author, “The Window may be Closing for Voluntary Disclosure of Offshore Holdings” Tax Litigation (2017) Volume XX, No. 3 (Toronto: Federated Press).

Author, “In the Headlines – Herman Grad 2000 Family Trust: Yet Another Cautionary Tale of Trust Residence” STEP Inside (2017), Volume 16, Issue No. 1 (Toronto: STEP Canada).

Co-Author, “AES and Riopel: Implications for the Common Law Remedy of Rectification” Tax Litigation, (2013) Volume XIX, No. 2, 1146-1149 (Toronto: Federated Press).

Author, “Beneficial Ownership in Canada's Tax Treaties” Corporate Finance (2012) Volume XVIII, No. 3 2136-38 (Toronto: Federated Press).

Author, “Part XIII Withholding on Payments to Foreign Intermediaries” Corporate Finance, (2012) Volume XVIII, No. 1, 2082-83 (Toronto: Federated Press).

Author, “Hedging Foreign Exchange Exposure of Balance Sheet Items” Corporate Finance, (2011) Volume XVII, No.1, 1941-1943 (Toronto: Federated Press).

Author, “Trust Validity and Residency: Federal Court of Appeal Decisions in Antle and Garron” Tax Litigation, (2011) Volume XVII, No. 4, 1075-1078 (Toronto: Federated Press).

Author, “Laerstate and Corporate Residence: Ripples from Across the Pond” Corporate Finance, (2009) Volume XVI, No. 2, 1825-1828 (Toronto: Federated Press).

Insights

Education

  • JD (Dean's Silver Scholar), Queen’s University, 2008
  • B.Sc. in Physics (with Distinction), Western University, 2004
  • Artist’s Diploma in Piano Performance (with Distinction), Western University, 2004
  • CPA In-Depth Tax Course, Parts I and II

Expertise

Tax
Tax Controversy/Tax Litigation