Dominic Belley is a tax litigator. He has represented taxpayers against federal, provincial and municipal tax authorities in civil, commercial, criminal and constitutional matters before the Court of Quebec, the Quebec Superior Court, the Québec Court of Appeal, the BC Supreme Court, the Alberta Court of King’s Bench, the Ontario Superior Court of Justice, the Nova Scotia Supreme Court, the Tax Court of Canada, the Federal Court and the Federal Court of Appeal. His domestic tax experience includes the general anti-avoidance rule (GAAR), tax on capital, the goods and services tax (GST), interest deductibility, hybrid transactions, the capital gains exemption, capital cost allowance, debt forgiveness, taxation of partnerships, trusts and estates, scientific research and experimental development (SR&ED), real estate, stock options, protection of tax information and cancellation of penalties. His international tax experience includes transfer pricing, foreign accrual property income (FAPI), residency, corporate migrations, the thin capitalization rules, de facto control by non-residents, international and inter-provincial allocation of income, anti-discrimination treaty provisions, and access to and protection of tax information through tax conventions.
