Brandon Siegal is an associate in our Tax Group. His practice focuses on tax litigation and tax dispute resolution with an emphasis on transfer pricing. He is proud to be a member of the International Tax Review's 2011-2012 Tax Disputes Firm of the Year (Canada).
Mr. Siegal has a unique understanding of both the government and judicial perspectives on resolving tax disputes. Prior to joining McCarthy Tétrault, Mr. Siegal represented the Canada Revenue Agency as Counsel for the Department of Justice for over five years and served as a clerk to the Judges of the Tax Court of Canada.
An experienced tax litigator who appears regularly before the Tax Court of Canada, Mr. Siegal has also appeared before the Federal Court and argued successfully before the Federal Court of Appeal on multiple occasions. In addition, he has negotiated settlements in hundreds of tax disputes.
Mr. Siegal has significant experience in resolving disputes relating to transfer pricing, the Canada-US treaty, tax shelters, aboriginal taxation issues, the inclusion income and deductibility of business expenses, commodity taxes, director liability assessments, the taxation of stock options, employment status, statutory penalties, and judicial review of Canada Revenue Agency decisions.
Some of Mr. Siegal's notable cases include:
ˇ OLTCPI INC. and The Minister of National Revenue, 2010 FCA 74, affirming 2008 TCC 470 - Treatment of placement agency workers for the purposes of employment insurance benefits
ˇ TD SECURITIES (USA) LLC. v. Her Majesty the Queen, 2010 TCC 18 - Treatment of Limited Liability Corporation (LLC) for the purposes of the Canada-Us Tax Treaty
Mr. Siegal obtained his LL.B. from the University of Ottawa (cum laude) in 2004. He received his Masters in Taxation from the University of Waterloo in 2007 and a Bachelor of Commerce from the Rotman School of Business at the University of Toronto in 2001. He is a member of the Canadian Tax Foundation, the Ontario Bar Association (Taxation Law Section) and the Advocates Society.