Angelo
Gentile
Partner
Angelo is Co-Leader of the firm's Tax Controversy/Tax Litigation Group and a member of the Tax Group. His practice focuses on tax litigation and commodity tax, including goods and services tax/harmonized sales tax (GST/HST) and provincial sales taxes. Angelo has extensive experience in resolving tax disputes involving GST/HST, income tax, CPP/EI, excise taxes, as well as the Ontario land transfer tax, Ontario employer health tax and Ontario tobacco tax.
Angelo is a natural problem solver. His deep knowledge and personable approach allow him to resolve his clients’ tax issues and disputes on an expedited basis, particularly when negotiating with the Department of Justice and the Canada Revenue Agency. His open and honest communication quickly instils in his clients a confidence that he is looking out for their best interests.
He has been successful in resolving a wide range of tax disputes at early stages of the process. Particularly in the field of GST/HST, Angelo’s in-depth knowledge of the legislation, coupled with his practical knowledge of the tax litigation process and the CRA administrative decision-making process, allows him to arrive at creative solutions to tax disputes that would have otherwise proceeded to trial. However, if a dispute cannot be resolved before trial, Angelo has experience representing clients before the Tax Court of Canada, the Federal Court, the Federal Court of Appeal and the Superior Court of Justice. Angelo also represents clients in making voluntary disclosures with the CRA and the Ontario Ministry of Finance.
Angelo advises Canadian and non-resident clients across a variety of industries, including real estate, financial services, retail, natural resources, health care, energy, communications, technology and manufacturing. In addition, Angelo advises clients in the charitable and not-for-profit sector.
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Professional Involvement
Memberships
- Canadian Bar Association (Commodity Tax Customs and Trade Section)
- GST Leaders Forum, a group established by the CPA of the most prominent GST/HST accountants and lawyers from across Canada
- Canadian Tax Foundation
- Law Society of Ontario
- Ontario Bar Association
Community Involvement
- Advisor/Mentor, Pro Bono Students Canada/Tax Court of Canada Pro Bono Project
Co-Presenter, "GST/HST – An Update and Review for the Non-Specialist," Ontario Tax Conference, October 28-29, 2024.
Presenter, “Indirect Tax Update for Non-Indirect Tax Practitioners," Canadian Tax Foundation 74th Annual Tax Conference, November 27-29, 2022.
Presenter, “Seller Beware! New Canadian Sales Tax Changes for Online Sellers,” AJAG Professional Development, June 11, 2021.
Presenter, “Duty of Care Owed to Taxpayers,” Chartered Professional Accountants Commodity Tax Symposium, October 24, 2019.
Presenter, “Case Law Update,” Chartered Professional Accountants Commodity Tax Symposium, October 16, 2018.
Presenter, "The Québec Runaway Bride: Reflections on the Canadian Indirect Tax Harmonization Process," Chartered Professional Accountants Commodity Tax Symposium, October 25, 2016.
Presenter, "Protecting Sensitive Tax Data & Nuances of Tax Litigation," The Institute of Law Clerks of Ontario, Just For Law, 26th Annual Conference, May 13, 2016.
Presenter, "Commodity Tax – Case Law Update," Tax Executives' Institute 50th Annual Canadian Tax Conference, May 3, 2016.
Presenter, "Unsuspecting Applications of the Fair Market Value Rule: Defending Challenges on Audit," Chartered Professional Accountants, September 29, 2015.
Presenter, "Directors' Liability for Unremitted Corporate Taxes: What Every Director Needs to Know," Continuing Professional Development Bootcamp, Toronto, November 12, 2014.
Presenter, "Tax and Privilege: A Primer," Continuing Professional Development Bootcamp, Toronto, November 30, 2011.
Presenter, "Case Law Update: While You Were Away This Summer," Ontario Bar Association Tax Law Section, September 21, 2011.
Presenter, "Case Law Update: A Fast and Furious Survey of Recent Decisions," Ontario Bar Association Tax Law Section, April 14, 2011.
Presenter, Canadian Tax Foundation Young Practitioners (Toronto), "HST: Key Issues of the Day," January 26, 2011.
Co-Author, "To Claim or Not to Claim – The New Age for Input Tax Credit Controversy," Tax Profile, December 2024.
Co-Author, "Canada Revenue Agency Extends Filing Deadline for Underused Housing Tax – Again," Aird & Berlis LLP, October 31, 2023.
Co-Author, "Beginning of a New Rental Construction Boom? Temporary GST Exemption for Purpose-Built Residential Rental Properties Sparks Growth Potential," Aird & Berlis LLP, September 28, 2023.
Co-Author, "Canada Country Report," Taxation of Crypto Assets, Wolters Kluwer, November 13, 2020.
Co-Author, “Duty of Care Owed to Taxpayers … And What to Do When Dealings with the CRA Go Sideways,” 2019 CPA Commodity Tax Symposium, October 2019.
Co-Author, “Callidus Capital Corporation v. Her Majesty the Queen,” Sales Tax, Customs & Trade, Federated Press, Volume XVI, No. 2, 2019.
Co-Author, “Case Law Update: 2018 CPA Commodity Tax Symposium,” 2018 CPA Commodity Tax Symposium, October 2018.
Author, “Unsuspecting Applications of Fair Market Value in the Excise Tax Act,” 2015 CPA Commodity Tax Symposium, September 2015 (Awarded the Norman Guérin Award).
Co-Author, "Case Law Update," 2012 CPA Commodity Tax Symposium, September 2012.
"Bozzer: An Interesting Victory for All Canadian Taxpayers," Tax Topics, August 2011.
"Husky Oil Limited v. The Queen: Clarifying the Scope of the Amalgamation Anti-Avoidance Rule," Tax Litigation Journal, Federated Press, Volume XVII, No. 3, 2010.
Contributor, Canadian Transfer Pricing, CCH Canadian Limited, 2nd Edition.
Co-Author, "New Litigation Process Conference Rules in Tax Court Proceedings," Tax Litigation Journal, Federated Press, Volume XVI, No. 4, 2010.
Co-Author, "Trends in Sales Tax Litigation," Report on the 2008 Canadian Tax Foundation Conference, 2009.
Co-Author, "GST and Commodity Tax Issues in Cross-Border Transactions: Expecting the Unexpected," Report on the 2007 Canadian Tax Foundation Conference, 2008.
Contributing Writer, "Federal Tax Practice," CCH Canadian Limited.
Co-Author, "Limit the Uncertainty" (regarding the scope of limitation periods in tax assessments), CA Magazine, April 2006.
Contributing Writer, "Charities, Non-Profits and Philanthropy Under the Income Tax Act," CCH Canadian Limited, 2006.