Carrie D'Elia

Carrie D'Elia

Partner, Tax

Contact Information

tel: 416.862.4220



Bar Admission

Ontario, 2002


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



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.

    • 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

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

  • Osler Federal Budget Briefing 2024

    Speaker, April 18, 2024

  • Managing Transfer Pricing Audits and Disputes

    Speaker, Toronto, January 14, 2020

  • 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

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

  • 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).