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Louise R.
Summerhill

Partner
  • lsummerhill@airdberlis.com
  • 416.865.3416
Office:
  • Toronto Office
Call to Bar:
Admitted to the Ontario Bar: 1990
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  7. Louise R. Summerhill

A creative thinker and natural problem solver, Louise continuously looks for new ways to approach and resolve her clients’ tax issues. Her technical expertise and knowledge of her clients’ businesses leads to solutions others may not see. When she takes matters to court, her strong advocacy skills are evident in her straightforward yet detailed presentation of the facts.

Louise is a member of the firm's Tax Group, Co-Leader of the Tax Controversy/Tax Litigation Group, and member of the Charities & Not-for-Profits Group. She practises almost exclusively in the area of tax litigation. She provides support and advocacy at the audit stage, through the objection procedure and in court if necessary. Louise also has extensive experience advising clients on transfer pricing, goods and services tax, provincial tax and federal income tax and charity law issues. 

She has appeared in the Tax Court of Canada, the Federal Court of Appeal, the Ontario Superior Court and the Ontario Court of Appeal. Louise was formerly the Chair of the Student Committee for the firm and Co-Chair of the firm's Women's Initiative.

Louise has been with Aird & Berlis since summering with the firm in 1987. 

Click here to learn more about Louise. 

 

Expertise

  • Tax Controversy/Tax Litigation
  • Tax
  • Charities & Not-for-Profits

Representative Matters

Representative Matter

L.F. Management and Investment Successful in Tax Court of Canada Decision

The Tax Court of Canada released the decision of L.F. Management and Investment S.A.R.L. v. The King, 2023 TCC 167, which addresses beneficial ownership and the general anti-avoidance rule in the context of Canada’s tax treaties with Luxembourg and Barbados.

December 13, 2023

Representative Matter

Aird & Berlis Acts for the Ontario Ministry of Economic Development in its Winning Bid for Volkswagen Gigafactory

The Ontario Ministry of Economic Development, Job Creation and Trade successfully bid for Volkswagen’s first overseas gigafactory, which will be built in St. Thomas.

May 16, 2023

Representative Matter

Federal Court Dismisses Motion to Strike Judicial Review Application on Voluntary Disclosure

On March 13, 2022, a prothonotary of the Federal Court of Canada dismissed the Crown’s motion to strike the judicial review application of Milgram Foundation.

April 22, 2022

Representative Matter

Tax Court Allows Unclaimed Rebates for Tax Paid in Error to Subcontractors

On March 17, 2022, The Tax Court of Canada allowed the GST/HST appeal of Mediclean Incorporated, a professional cleaning service company that engages cleaners as subcontractors to provide these services.

April 22, 2022

Representative Matter

Mediclean Successful in Tax Court of Canada

Mediclean Inc. was recently successful in winning an appeal in the Tax Court of Canada. Mediclean Inc. had appealed decisions dated March 21, 2016, under the Canada Pension Plan and the Employment Insurance Act that had held that an individual contractor was engaged in pensionable and insurable employment.

April 17, 2017

Representative Matter

Triple M Successful in Tax Court of Canada

Triple M Metal LP was recently successful in winning an appeal in the Tax Court of Canada. Triple M appealed a Notice of Confirmation dated September 15, 2014 relating to an Ontario Goods and Services Tax/Harmonized Sales Tax reassessment covering the period from August 1, 2010 to September 30, 2010.

February 06, 2017

Professional Involvement

Memberships

  • The Advocates' Society
  • Canadian Tax Foundation
  • Thomas More Lawyers' Guild of Toronto
  • Women Presidents' Organization (2004 - 2009)

Community Involvement

  • Birthright International, Board of Directors
  • Philip Aziz Centre for Hospice Care, Chair, Board of Directors

Teaching Engagements

  • Co-creator and former adjunct professor of "The Course of a Transaction," Osgoode Hall Law School

Presenter, “Audit to Appeal – Navigating the Tax Litigation Process,” AJAG, September 27, 2019.

Presenter, “What’s New at CRA/Real Estate Transactions,” Professional Accountants PD Network, February 5, 2019.

Presenter, “What’s New at CRA?,” AJAG Presentation, November 22, 2018.

Presenter, “What's New at the CRA,” Education Consortium, October 24, 2018.

Presenter, "CRA Bag of Tricks: An Update on Audit Initiatives, Voluntary Disclosures and Recent Case Law," AJAG Seminar, October 27, 2017.

Presenter, "Topical Tax Issues and Recent Cases," AJAG Seminar, November 1, 2016.

Presenter, "CRA Real Estate Audit Project – The Scary Truth," Aird & Berlis LLP Seminar, June 1, 2016.

Presenter, "Tax Litigation - Tips & Traps," AJAG Seminar, January 20, 2016.

Presenter, "Tax-A Mixed Bag of Things You Need to Know," Education Consortium, November 11, 2015. 

Presenter, "Settlements: Tax Traps For The Unwary," Aird & Berlis LLP Seminar, January 28, 2015.

Presenter, "Tax Litigation: Navigating the Process From Audit Through Appeal," AJAG Seminar, January 15, 2015.

Presenter, "Update on Tax Litigation," Aird & Berlis LLP Tax Breakfast, October 1, 2013.

"Changes Are Coming to the Voluntary Disclosures Program," Aird & Berlis LLP Tax News Flash, March 2, 2017.

"Ontario Reverses Land Transfer Tax Partnership Exemption," Aird & Berlis LLP Tax News Flash, February 22, 2016.

"Beneficial Ownership of Royalties – Tax Court Respects Corporate Form," The Bottom Line, February 2012.

"Beneficial Ownership: Another Canadian Victory for Taxpayers," Tax Profile, February 2012.

"CRA ''Targets High Net Worth' Individuals," June 7, 2011. 

"Canada’s Transfer Pricing Rules," February 2011.

"GAAR – Common Sense Prevails," The Bottom Line, June 2009.

"The Murky Waters of Director's Liability after Corporate Revival," The Bottom Line, May 2009 (co-written with articling student Diana Yeung).

"Taxpayer Prevails – Again – on Beneficial Ownership," The Bottom Line, April 2009 (co-written with Barbara Worndl).

"Another Part to the Sales Tax Exemption for Manufacturers," The Bottom Line, January 2009.

"'More Than Five Full-Time Employees' – The Sensible Approach to Defining a Term," The Bottom Line, Mid-November 2008.

"More Treaty Interpretation: What is a Fixed Place of Business?" The Bottom Line, Mid-October 2008.

"Redeemer Foundation; confirming the CRA's Broad Audit Power," The Bottom Line, October 2008 (co-written with Milo Prelevic).

"When is a Foreign Worker Remunerated in Canada?" The Bottom Line, August 2008.

"Scholarship Programs do not give Rise to Taxable Benefits," The Bottom Line, July 2008.

"Beneficial Ownership by Holding Company Respected," The Bottom Line, June 2008.

Related Publications

Article

Navigating Cross-Border Tax Controversy

August 30, 2023

Article

COVID-19 Travel Restrictions and Tax Residency Relief

May 22, 2020

Article

Tax Limitation and Appeal Periods Extended

May 22, 2020

Article

Highlights of the 2018 Federal Budget

February 27, 2018

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August 28, 2024

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September 05, 2023

Read More News

Related Videos

Tax Litigation Video Series

Tax Litigation Video Series - What to Do When the CRA Calls

Louise Summerhill shares important information on what to do if the CRA notifies you of an audit by phone call.

August 13, 2024

Tax Litigation Video Series

Tax Litigation Video Series - Introduction

The Aird & Berlis Tax Litigation Team is proud to introduce the Tax Litigation Video Series.

July 15, 2024

Education

  • LLB, University of Windsor, 1988
  • BA (Hons., with Distinction), English, Glendon Campus, York University, 1984
  • BA, English, St. Michael's College, University of Toronto, 1983
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