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Al-Nawaz Nanji

Al-Nawaz Nanji

Partner, Taxation


Contact Information

ananji@osler.com

tel: 416.862.6629

Office

Toronto

Bar Admission

Ontario, 2003

Education
  • University of Ottawa, M.B.A.
  • University of Ottawa, LL.B. (summa cum laude)
  • Carleton University, B. Comm.
  • CPA Indepth I, II and II
  • CPA Corporate Reorganizations
  • CPA Transfer Pricing Indepth I and II
  • CPA GST/HST Course
Language(s)
English

Al-Nawaz practices tax law, with a focus on litigation and dispute resolution.

He assists clients in resolving both income tax and GST/HST tax disputes with the Canada Revenue Agency and provincial tax authorities, including administrative and procedural matters such as dealing with requirement letters, privilege considerations and voluntary disclosures. He has appeared in tax matters before the Tax Court of Canada, Federal Court, Federal Court of Appeal and Ontario Superior Court of Justice.

He has extensive experience in tax dispute resolution and tax litigation.

He has co-taught Introduction to Taxation at the University of Ottawa and was a mooting advisor for the Bowman Tax Court Moot.

    • Canadian Imperial Bank of Commerce in its appeals to the Federal Court of Appeal on the GST treatment of Aeroplan Miles and the purchase of Visa services.
    • CIBC World Markets Inc. in its appeal to the Federal Court of Appeal on input tax credits on expenses incurred for exported services.
    • Compass Minerals in its appeal to the Federal Court of Appeal on transfer pricing penalties and in its appeal to the Tax Court of Canada on a transfer pricing competent authority agreement.
    • Bell Canada in its appeal to the Tax Court on recaptured input tax credits.
    • Royal Bank of Canada in its appeal to the Tax Court on the GST treatment of services relating to creditor insurance.
    • Highlands Fuel Delivery in its appeal to the Federal Court on the refund of Federal Excise Tax.
    • Metrogate in its appeal to the Tax Court of Canada on the Ontario transitional new housing rebate.
    • Brompton in its appeal to the Ontario Court of Appeal on the interpretation of a tax representation and in its appeal to the Tax Court under the General Anti-Avoidance Rule.
    • Sirius XM in its appeal to the Tax Court on the deductibility of expenses.
    • Brookfield Asset Management in its appeal to the Tax Court on the income tax treatment of interest rate swaps.
    • Hudson’s Bay Company in its appeal to the Tax Court on scientific, research and experimental development expenses.
    • Slaight Communications in its rectification application to the Ontario Superior Court of Justice.

  • International Tax Review: Ranked in International Tax Review: Tax Controversy: recognized as a Highly Regarded lawyer
  • Rated best speaker at Acumen Taxation of Corporate Finance and Financial Structures on the subject of Transfer Pricing Implications of Financial Strategies and Structures
  • Ontario Bar Admission awards: The Osgoode Society for Canadian Legal History Prize (top 25) and McCarthy Tétrault Business Law Prize
  • Received University of Ottawa Silver Medal
  • Law school awards: Tax Executives Institute Prize, Stikeman Elliott/Carswell National Tax Award, Bennett Jones LLP Prize, Osler, Hoskin & Harcourt Prize (business law and advanced taxation)
  • Canadian Corporate/Securities Law Moot Court Competition (1st factum, 4th oralist)

  • Chairman, His Highness Prince Aga Khan Shia Imami Ismaili National Conciliation and Arbitration Board for Canada (2019 - Present)
  • Adjunct Lecturer, University of Toronto (2014 - Present)

  • Canadian Tax Foundation
  • Canadian Bar Association
  • Ontario Bar Association (Tax Section)

  • Co-presented at the 2017 Commodity Tax Symposium on “Transparency and Accountability: What Tax Authorities Can and Cannot Ask for”
  • What Multinationals Need to Know About Canada Revenue Agency’s Two New Transfer Pricing Memoranda, TPM-15 and TPM-16: Onerous Canadian Transfer Pricing Documentation Required (Tax Management International Journal, Volume 44, No. 6, June 2015)
  • Co-presented at the 2014 Tax Officer’s Section of the Canadian Life and Health Insurance Association Annual Conference on “Best Practices in Transfer Pricing from Contemporaneous Documentation to Litigation"
  • Various case comments (published on Knotia)
  • Acumen Taxation of Corporate Finance and Financial Structures on the subject of Transfer Pricing Implications of Financial Strategies and Structures (June, 2012)
  • Federated Press Assessments, Objections and the Appeals Process (May, 2012)
  • Federal Court of Appeal reverses MacKay (Tax Litigation Journal, Volume XVI, No. 2, 2009)
  • Breaking Up a Business or Surplus Stripping? GAAR Considerations in McMullen v. The Queen (Tax Litigation Journal, Volume XV, No. 1, 2007)
  • Supreme Court Rules on First GAAR Case (Ottawa Business Journal, Dec. 2005)