Joanne Vandale is a Partner in Osler’s National Tax Group with a practice focused exclusively on tax litigation and dispute resolution. With nearly two decades of experience representing clients in complex tax matters, Joanne is widely recognized for her strategic advocacy and deep understanding of Canada’s tax landscape.
She regularly represents clients before the Tax Court of Canada, the Federal Court of Appeal, and the Supreme Court of Canada, guiding corporations, partnerships, trusts and individuals through audits, objections, and litigation against the Canada Revenue Agency and provincial tax authorities. Her expertise spans a broad range of contentious tax issues, including the general anti-avoidance rule (GAAR), resource taxation, transfer pricing, executive compensation, and SR&ED tax credits.
Joanne is known for combining technical excellence with a practical, client-focused approach. She has acted on numerous high-profile cases and is recognized for her ability to navigate complex tax disputes. She has acted for major corporations across sectors such as energy, natural resources, agriculture, and technology.
Joanne is actively involved in the Canadian tax community. She is a past chair of the Canadian Bar Association’s Tax Specialists (South) section and a former board member of the Canadian Petroleum Tax Society. She is frequently invited to speak and write on tax controversy topics.
Representative Work
- West Fraser CDN. Ventures (2015) Ltd. in its appeal regarding the proper characterization of a cross-border “repo” transaction for tax purposes.
- Hopewell Land Master Corporation in its appeal regarding the proper characterization of a debt investment from a third party in a residential real estate development in Calgary
- J.D. Irving Limited in respect of Revenu Québec’s reassessments denying the tax benefits associated with a related group loss consolidation transaction premised on recharacterizing the legal agreements entered into by the taxpayer
- Athabasca Oil Corporation in its appeal relating to whether the disposition of shares of its wholly-owned subsidiary that held a 40% interest in an oilsands project was on account of income or capital
- ExxonMobil Canada Ltd. in an appeal in respect of the character of its gain arising on the sale of its interest in certain geographic production areas in Western Canada
- Suncor Energy Inc. (as successor to Petro-Canada) in its transfer pricing appeal relating to the deductibility of losses realized in Canada on the settlement of hedging contracts relating to its UK operations
- Devon Canada Corporation v. The Queen, 2018 TCC 170 – Appeal respecting the tax treatment of stock option surrender payments made on an acquisition of control
- Superior Plus Corp. v. The Queen, 2016 TCC 217 – Motion to compel the Crown to answer follow-up questions on discovery
- Superior Plus Corp. v. The Queen, 2015 TCC 132, & 2015 FCA 241 – Motion to compel the Crown to answer questions/produce documents on discovery and defending motion by the Crown to compel production of opinions protected by solicitor-client privilege in the context of a SIFT conversion case
- Suncor Energy Inc. (as successor to Petro-Canada) in its transfer pricing appeal relating to the deductibility of losses realized in Canada on the settlement of hedging contracts relating to its UK operations
- Devon Canada Corporation v. The Queen, 2018 TCC 170 – Appeal respecting the tax treatment of stock option surrender payments made on an acquisition of control
- Superior Plus Corp. v. The Queen, 2016 TCC 217 – Motion to compel the Crown to answer follow-up questions on discovery
- Superior Plus Corp. v. The Queen, 2015 TCC 132, & 2015 FCA 241 – Motion to compel the Crown to answer questions/produce documents on discovery and defending motion by the Crown to compel production of opinions protected by solicitor-client privilege in the context of a SIFT conversion case
Latest Insights
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Osler Update March 1, 2022
Quebec Court of Appeal provides decision on loss consolidation transactions
On February 17, 2022, the Quebec Court of Appeal released its decision in Agence du revenu du Québec vs. J.D. Irving Limited, in which it dismissed...
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Webinar December 2, 2021
Practical Implications of Recent Developments in the Courts
Presented by Osler and the Tax Executives Institute The Osler Western Canada team will address recent developments in tax cases and CRA...
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Osler Update July 19, 2021
Scientific Research and Experimental Development: Is improving cost efficiency relevant?
In 2012 and 2013, 6398316 Canada Inc. designed and successfully constructed a house that required no grid-tied fuel for heating and cooling (such as...
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Awards and Recognition
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Chambers Canada: Canada’s Leading Lawyers for Business: Recognized in Tax: Litigation
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Lexpert: Rising Stars: Recognized as a Lexpert Rising Star: Leading Lawyers Under 40
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The Canadian Legal Lexpert Directory: Recognized in Corporate Tax; Litigation – Corporate Tax
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Best Lawyers: Recognized in Tax Law
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International Tax Review: Recognized in Tax Controversy; Women in Tax; Recognized as a Highly Regarded Lawyer
Media Mentions
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Osler News August 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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Media Mentions February 15, 2023
Concern grows over Canada’s mission to update tax avoidance rule – Bloomberg Tax
The tax landscape in Canada may be on the brink of a new era. The federal government is considering changes to the general anti-avoidance rule,...
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Osler News December 6, 2022
New tax disputes publication featuring contributions by Osler lawyers now available
The Canadian Tax Foundation has just published a new book on Canadian tax disputes.
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Osler News October 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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Speaking and Writing
Speaking Engagements
Canadian Tax Foundation 75th Annual Conference
Speaker, Montréal, November 26-28, 2023
Supreme Court guidance on Canada’s international tax regime: Implications of Alta Energy and Loblaw
Speaker, Calgary, December 16, 2021
“Recent Cases”, June 2021, Canadian Petroleum Tax Society, 2021 Annual Conference, (with Kaitlin Gray).
Current Cases and Audit Issues, June 7, 2018, Canadian Petroleum Tax Society, 2018 Annual Conference (with Edward Rowe).
Strategic Considerations for Managing Tax Risk, November 15, 2017, Tax Executives Institute, Vancouver Chapter.
Commercial Vehicles – Select Issues in Defining Legal Relationships, November 27-29, 2016, Canadian Tax Foundation 68th Annual Conference (with Heather DiGregorio).
Recent Tax Cases of Interest, October 22, 2015, Canadian Petroleum Tax Society, 2015 Fall Lecture Series (with Colena Der).
Recent Cases on Debt and Interest and Other Notable Cases, April 25, 2015, Canadian Bar Association – Taxation Specialist (with Colena Der).
Qualifying Environmental Trusts, June 4, 2014, Canadian Petroleum Tax Society, 2014 Annual Conference (with Edward Rowe).
Update on the Bump Rules – Recent Developments, November 12, 2013, Canadian Petroleum Tax Society, 2013 Fall Lecture Series (with Alan Rautenberg).
Recent Transactions, October 26, 2011, Canadian Petroleum Tax Society, 2011 Fall Lecture Series (with Greg Johnson).
Income and Royalty Trust Conversions, November 3, 2009, Canadian Petroleum Tax Society, 2009 Fall Lecture Series (with Greg Johnson).
Sifting Through the Wreckage: The Rise and Demise of Canadian Income Trusts, May 29, 2007, Prairie Provinces Tax Conference 2007 (with Scott Bodie).
Published Work
- “Concern Grows Over Canada’s Mission to Update Tax Avoidance Rule”, Bloomberg Tax, February 15, 2023 (with Pooja Mihailvich)
- “Tax Disputes in Canada: The Path Forward”, (2020) edited by Pooja Mihailovich and John Sorensen.
- Joanne co-authored chapter 18 titled “Document Disclosure and Discovery”
- “SR&ED is Improving Cost Efficiency Relevant?”, Tax for the Owner-Manager, Vol. 21, No. 3 (2021) with Jennie Han
- “Nil Assessments Are Not a “Nothing” Tax Litigation (Federated Press) Vol. XXIII, No. 3 (2020) (with Daniel Downie).
- “Commercial Vehicles – Select Issues in Defining Legal Relationships”, November 28, 2016, Canadian Tax Foundation 68th Annual Conference (with Heather DiGregorio).
- “Speculation on the Application of AES to Common-Law Rectification”, Vol. 4, No. 1. (2014) Canadian Tax Focus.
- “RRSP Anti-Avoidance Rules”, September 26, 2011, Canadian Bar Association – Taxation Specialists.
- “Sifting Through the Wreckage: The Rise and Demise of Canadian Income Trusts”, May 29, 2007, Prairie Provinces Tax Conference 2007 (with Scott Bodie).
- “Tax Implications of Alberta Corporate Law Changes”, Resource Sector Taxation, Vol. III, No. 4, (2005) (with Alan Ross).
- “Income Tax Considerations Arising from Amendments to the Business Corporations Act (Alberta)”, Vol. 18, No. 1, Canadian Petroleum Tax Journal (2005) (with Alan Ross).
Credentials
Education
- University of Alberta, LL.B.
- University of Calgary, B.A. English
Languages
- English
Professional Affiliations
- Canadian Tax Foundation
- Canadian Petroleum Tax Society
- International Fiscal Association
- American Bar Association
- Advocates’ Society
- Law Society of Alberta
- Canadian Bar Association
