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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.
  • CICA Indepth I, II and II
  • CICA Corporate Reorganizations
  • CICA Transfer Pricing Indepth I and II
Language(s)
English

Al-Nawaz practises tax law, with a focus on litigation and dispute resolution. He also advises on various tax planning matters. He represents clients in tax disputes with the Canada Revenue Agency and provincial tax authorities as well as tax litigation before the Tax Court of Canada, Federal Court of Appeal and Supreme Court of Canada and Ontario Superior Court of Justice. He also represents clients before the Federal Court in respect of judicial reviews and before the Ontario Superior Court of Justice in respect of rectification applications.

He has extensive experience in tax dispute resolution, tax litigation, corporate and international taxation. He has acted for clients in tax disputes and transaction tax matters involving various tax issues, including transfer pricing, the general anti-avoidance rule in the federal and provincial context, corporate control, shareholder and employee benefits, deductibility of settlement payments and other types of expenses, residence for tax purposes, and a range of administrative and procedural tax matters (including requirement letters, access to information and privilege related issues).

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

    • Sifto Canada Corp. v. The Queen, 2014-895(IT)G and 2014-896(IT)G
    • Canada (National Revenue) v. Sifto Canada Corp., 2014 FCA 140
    • Hudson’s Bay Company v. The Queen, 2012-862(IT)G
    • Sismondo et al. v. The Queen, 2012-2553(IT)G, 2012-2555(IT)G
    • Slaight and Slaight Communications v. Attorney General of Canada, CV-12-447489
    • Guilbault v. The Queen, 2011 TCC 394
    • Pickard v. The Queen, 2010 TCC 535
    • FMC Technologies Company v. The Queen, 2008 FC 871, aff’d 2009 FCA 217, leave to appeal denied, Supreme Court File No. 33336
    • The Queen v. Okonski, A-161-08
    • Ellis v. The Queen, 2007 TCC 289 aff’d 2008 FCA 92
    • Sedona Networks Corporation v. The Queen, 2006 TCC 80 aff’d 2007 FCA 169
    • Dean v. The Queen, 2007 TCC 257
    • Avotus Corporation v. The Queen, 2006 TCC 505
    • 1102552 Ontario Limited, Algonquin Industries International Inc., and Algonquin Group Inc. v. The Queen, T-1347-05
    • Gaudreau v. The Queen, 2005 FCA 388 

International Tax Review

  • International Tax Review: Tax Controversy, 2017-2019: 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.

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).

  • Canadian Tax Foundation
  • Canadian Bar Association
  • Ontario Bar Association (Tax Section)
  • National Member, His Highness Prince Aga Khan Shia Imami Ismaili National Conciliation and Arbitration Board for Canada (2012-15)  

  • 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 5-6, 2012)
  • Federated Press Assessments, Objections and the Appeals Process (May 14, 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)