Lawyer Profile
David R. Davies
Toronto, Ontario
Overview
David is a tax litigator who specializes in challenging adverse tax reassessments issued by the Canada Revenue Agency.
An 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. If they succeed, then, however unappreciative the [tax agency] or fellow taxpayers may be of their ingenuity, they cannot be compelled to pay an increased tax.”
The above quote reflects David’s philosophy. The Canada Revenue Agency (CRA) can only collect amounts to which it is legally entitled, and no more. He becomes involved when the CRA tries to insist that his clients pay more than required by law.
David is one of the top creative tax problem solvers in the country. He zealously guards the interests of his clients to obtain the best result possible.
David’s clients are comprised largely of corporate taxpayers. He also represents high net worth individuals who have been targeted by the CRA. His is experienced in CRA audit management and in defending against CRA challenges to:
A tax reassessment can be successfully challenged either procedurally or substantively. David successfully uses his knowledge of procedure and administrative law to the advantage of numerous clients without ever having to get to the substantive merits of the reassessment. He has won numerous cases on the basis that income was assessed in the wrong year; or against the wrong taxpayer; or in a statute-barred year; or that the tax law itself was invalid.
A reassessment fought on the merits requires thorough analysis and preparation. There is no substitute for hard work, and he prides himself on his and his team’s ability to prepare a successful defence against a reassessment.
David started his career as a tax planner with Thorsteinssons LLP before turning to tax litigation. With a planning background, he understands the tax and commercial foundations of the transactions being challenged.
Practice Areas
Bar Information
Called to the bar: 1989 (BC)
