Carrie D’Elia

Carrie D’Elia is a partner in the firm’s tax department. Her practice includes tax disputes with the Canada Revenue Agency and provincial tax authorities across the country, as well as litigation before the Tax Court of Canada, Federal Court of Appeal, Supreme Court of Canada and provincial courts.

Carrie has been involved with tax issues including transfer pricing, tax avoidance in the federal and provincial contexts, the deductibility of settlement payments and other types of expenses, and Canadian tax aspects of mergers and acquisitions, in addition to a range of administrative and procedural matters specific to the tax area.


Representative Work

  • Her Majesty The Queen in Right of Alberta v. Husky Energy  Inc. – A case involving the application of Alberta’s General Anti-Avoidance Rule, response to application for leave to appeal to the Supreme Court of Canada, Case 34999
  • Canadian Imperial Bank of Commerce v. Her Majesty The Queen – Motion to strike pleadings and appeal of the motion decision, at the Tax Court of Canada and Federal Court of Appeal –  2011 TCC 568 , 2012 TCC 237
  • Inter-Leasing  Inc. v. The Minister of Revenue – A case involving the application of Ontario’s General Anti-Avoidance Rule, at the Ontario Superior Court, Ontario Court of Appeal and response  to  application  for  leave  to  appeal  to  the  Supreme  Court  of Canada, Court File No. 36117

Latest Insights

  • Webinar Apr 18, 2024

    Canadian Tax Law Insights: The 2024 federal budget and its implications for Canadian businesses

    Our National Tax Group lead an in-depth discussion of the 2024 federal budget and what it means for your business.

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    Canadian Tax Law Insights: The 2024 federal budget and its implications for Canadian businesses
  • Webinar Jun 13, 2023

    Canadian Tax Law Insights: Managing tax audits to prevent and resolve disputes with the CRA – Part 2

    Members of Osler’s Tax Group provide guidance and best practices for preventing and resolving tax disputes earlier, and more effectively, in light...

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    Canadian Tax Law Insights: Managing tax audits to prevent and resolve disputes with the CRA – Part 2
  • Blog Apr 8, 2022

    The perils of asserting privilege

    Canadian courts — up to and including the Supreme Court of Canada — have confirmed that solicitor-client privilege is a substantive...

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    The perils of asserting privilege

Awards and Recognition

  • International Tax Review World Tax Pratitioners Rankings: Recognized in Tax Controversy; Women in Tax: recognized as a Highly Regarded lawyer

Media Mentions

  • Osler News Aug 25, 2023

    Osler recognized as a Tier 1 firm in ITR’s World Tax Guide 2024

    Osler is proud to once again be recognized as a Tier 1 firm in the 2024 edition of the International Tax Review’s World Tax guide. Additionally, 19...

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  • Osler News Oct 4, 2021

    Osler recognized as a Tier 1 firm in ITR’s World Tax Guide 2022

    Osler has maintained its Tier 1 rankings in ITR’s World Tax Guide with 18 lawyers recognized as leaders in their field.

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  • Osler News Sep 29, 2020

    Osler earns Tier 1 rankings in ITR’s 2021 World Tax Guide

    Osler is proud to announce we have once again been recognized in Tier 1 of International Tax Review’s World Tax Guide 2021, earning top rankings in...

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  • Osler News Sep 30, 2019

    Osler recognized as a Tier 1 firm in ITR’s 2020 World Tax guide

    Osler is honoured to be once again recognized as a leading firm in the 2020 edition of International Tax Review’s World Tax guide, earning a Tier 1...

    Read more
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Speaking and Writing

Speaking Engagements

speaker 18/4/2024
Canadian Tax Law Insights: The 2024 federal budget and its implications for Canadian businesses
Read more
speaker 13/6/2023
Canadian Tax Law Insights: Managing tax audits to prevent and resolve disputes with the CRA – Part 2
Read more
speaker 14/1/2020
Managing Transfer Pricing Audits and Disputes
Read more

Privilege in the Tax World
Speaker, Toronto, November 23, 2016

Tax Research Refresher Workshop, Canadian Tax Foundation Annual Tax Conference
Speaker, Vancouver, November 30, 2014

Published Work

  • Observations on the OECD Discussion Draft on Intangibles (co-authored with Richard Tremblay), Bloomberg BNA Tax Management International Journal Vol. 41, No. 10, October 12, 2012.
  • “Now that I Have Paid You … Are Your Fees Deductible? The Tax Treatment of Transaction Costs – Part I and II” (2004) IX (4) Business Vehicles 466 (co-authored with Ted Citrome), cited in Potash Corporation of Saskatchewan Inc. v. The Queen, 2011 TCC 213.
  • Barclays Mercantile – A Case Comment (co-authored with Maria Tatarova), OBA Taxation Law Newsletter Volume 15, No. 2, March 2005.
  • OECD Revised Discussion Draft on Attribution of Profits to a PE: Commentary and Canadian Implications (co-authored with Maria Tatarova), Tax Planning International Review, January 20, 2005.
  • Case Comment: Ellis Vision Inc. v. The Queen, OBA Taxation Law Newsletter Volume 14, No. 3, May 2004.
  • Costing Nothing to Put a Twinkle in Someone’s Eye – The Johnson & Johnson Decision, OBA Taxation Law Newsletter Volume 13, No. 4, May 2003 (co-authored with Chia-yi Chua).

Credentials

Education

  • Osgoode Hall Law School, LL.B.
  • University of Toronto, B.A. (Hons.) (English)

Languages

  • English

Professional Affiliations

  • Canadian Bar Association
  • Ontario Bar Association
  • Canadian Tax Foundation
  • International Fiscal Association
  • The Advocates' Society