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While its complexity and highly technical nature are what usually tend to turn most law students away from tax, this is what initially drew me to it. It is undoubtedly one of the most highly intellectually stimulating areas of law. It marries legal concepts from several different other fields of law ranging from corporate to property law and more.
As a summer student, I was keen on pursuing my interest in tax. I had the opportunity to work on several different mandates with the lawyers of the tax group and was also invited to attend the group’s biweekly lunches.
As an articling student, I worked on a variety of mandates both in tax litigation and tax planning, including drafting Notices of Objection, Notices of Appeal, Advance Tax Ruling Requests and various memoranda both for internal and external purposes. I also had the chance to give presentations at the Montreal as well as national tax group lunches. In being called upon to give the presentations, I was asked to summarize recent cases rendered by the Tax Court of Canada and Federal Court of Appeal regarding subjects such as the application of the General Anti-Avoidance Rule, the determination of a corporation’s status as a Canadian-Controlled Private Corporation and even whether or not the income earned as a victim of a ponzi-scheme is taxable income for the purposes of the Income Tax Act!
Although the thought of presenting to the Montreal tax group and especially the national tax group was intimidating at first, I now look forward to giving such presentations as they allow me to further my knowledge on the most recent issues being addressed by Canadian tax courts and also help me to develop my skills as a public speaker.
They all took pride in carefully explaining the facts and underlying legal issues in every mandate that they assigned to me. What’s more, I was able to freely exchange ideas about my mandates with each member of the group which proved to be an invaluable tool for me when faced with challenging legal issues.
The tax group has a very unique and exciting dynamic which I grew to appreciate more and more each day. The small size of the group allowed me to form strong interpersonal relationships with each lawyer, giving it the feel of a boutique firm while having all the resources of a top tier national law firm at my fingertips to execute my mandates. In short, articling with the tax group made me more enthusiastic about the practice of tax law than I have ever been.