Clifford
Rand
Partner
Admitted to the Ontario Bar: 1986
Cliff is a tax litigator with 30 years of experience who is committed to helping his clients resolve their tax controversies as efficiently as possible. He negotiates settlements with tax authorities or, when necessary, brings appeals and applications in the courts, including the Tax Court of Canada, the Federal Court of Canada, the Ontario Superior Court of Justice and the Supreme Court of Canada. Cliff applies his comprehensive knowledge of tax law to develop and implement strategies that get the best possible results for his clients.
Cliff is a partner and member of the Aird & Berlis Tax Group and Tax Controversy/Tax Litigation Group. In his practice, Cliff represents companies and other entities as well as individuals. He specializes in managing large and complex tax audits on behalf of taxpayers, including audits involving corporate reorganizations, cross-border transactions, transfer pricing, SR&ED credits and the general anti-avoidance rule.
Another important part of Cliff's practice is ensuring that the tax authorities operate within lawful parameters regarding demands for information and documents, and representing clients in applications to the courts for judicial review of decisions made by tax authorities regarding access to information, collections and other issues. Cliff also assists clients in correcting non-compliance issues and in rectifying transactions with unintended tax consequences.
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Other Languages
French
Professional Involvement
Community Involvement
- Member of the Board of Directors of the Sunnybrook (Hospital) Health Sciences Centre. Member of the Board of Directors of the Sunnybrook Foundation. Member of the Sunnybrook Foundation’s Executive Committee and Governing Council. Past-Chair of the Sunnybrook Foundation.
Teaching Engagements
- Law Professor, University of Windsor, Faculty of Law, (1984 - 1988)
"Transfer Pricing: Anticipating and Responding to New Challenges," International Bar Association Conference, March 3, 2022.
“Contested Settlements and Reliance on Rulings and APAs,” International Bar Association 10th London Finance and Capital Markets Virtual Tax Conference, February 2021.
“Bringing Motions in the Tax Court,” Law Clerk Seminar, Tax Court of Canada, Ottawa, September 2016.
“Tax Dispute Resolution Conference – A Day with the Judges of the Tax Court of Canada,” Canadian Tax Foundation, April 2015.
“Finding Solutions and Remedies for Taxpayers Involved in Tax Disputes,” Canadian Tax Foundation 66th Annual Conference, December 2014.
“Settlement Conferences,” presentation given to foreign judicial delegation, Tax Court of Canada, Ottawa, June 2014.
“Regard des avocats litige sur les derniers développements et la jurisprudence récente en matière de controverse fiscale,” Institut des Cadres Fiscalistes/TEI Inc., Montréal, May 2014.
“A Tax Litigator’s Perspective on Recent Case Law Affecting the Tax Controversy Process,” Tax Executives Institute Professional Development Day, Toronto, April 2014.
“Risk, Uncertainty and Opportunity in a Changing Tax Landscape,” Deloitte Global Tax Conference, March 2014.
“International/Transfer Pricing Audits – What You Need to Know,” Canada Revenue Agency & Professional Group, Breakfast Seminar, Toronto, February 2014.
“What’s New in the World of Canadian Tax Controversy?,” Tax Executives International, Navigating the New World Conference, November 2013.
“Motions,” Law Clerk Seminar Program, Tax Court of Canada, Ottawa, October 2013.
“The CRA’s New Approach to Large Business Compliance (ALBC) – Benefits and Drawbacks for Large Businesses,” Canadian Bank Tax Leaders Forum, March 2013.
“Perspectives on Canadian Tax Dispute Resolution,” Deloitte Global Tax Planning Conference, Americas, March 2013.
“Current Tax Cases,” Canada Revenue Agency & Professional Group, Breakfast Seminar, Toronto, February 2013.
“Tax Compliance: Administration & Dispute Resolution,” Chair, Rectification/Competent Authority panel, Canadian Tax Foundation Conference, Toronto, June 2012.
“Current Tax Cases,” Canada Revenue Agency & Professional Group, Breakfast Seminar, Toronto, June 2012.
“Current Tax Cases,” Canada Revenue Agency & Professional Group Breakfast Seminar, Toronto, February 2012.
BDO National Tax Specialists Conference, Toronto, January 2012.
“Current Tax Cases,” Canada Revenue Agency/Tax Professionals Breakfast Seminar, Toronto, November 2011.
“Motions,” Law Clerk Seminar Program, Tax Court of Canada, Ottawa, October 2011.
“Continuing Issues for General Practitioners Program,” Law Society of Upper Canada, Toronto September 2011.
“Current Tax Cases,” Canada Revenue Agency & Professional Group, Breakfast Seminar, Toronto, June 2011.
“A Comparative Look at Canada's Approach to Treaty Interpretation,” International Tax Seminar, International Fiscal Association, Toronto, May 2011.
“Audit Preparation: Counsel's Role,” 12th Annual Managing Tax Audits & Investigations Conference, Federated Press, Toronto, May 2011.
“Preparing for a Tax Audit and the Role of Counsel in Tax Audits,” 11th Annual Managing Tax Audits & Investigations Conference, Federated Press, Calgary, March 2011.
“Current Tax Cases,” Canada Revenue Agency Breakfast Seminar, Toronto, Ontario, February 2011.
“Copthorne Holdings Case Panel Discussion,” Faculty of Law, University of Toronto, January 2011.
“Transfer Pricing and Dispute Resolution in a World of Changing Rules & Guidelines,” Canadian Tax Foundation Conference Report 2016: Report of Proceedings of the Sixty-Eighth Tax Conference, 2017.
“Managing the Minister’s Collection Powers on Behalf of Large Corporations,” Canadian Tax Foundation Conference Report 2014: Report of Proceedings of the Sixty-Sixth Tax Conference, 2015.
“Current Cases,” Canadian Tax Foundation Conference Report 2011: Report of Proceedings of the Sixty-Third Tax Conference, 2012.