Élisabeth Robichaud

Partner

Elisabeth Robichaud

Élisabeth Robichaud

Partner

Expertise
Bar Admissions
  • Québec, 2011

Élisabeth’s practice is focused on litigation and the settlement of tax disputes before tax authorities and the courts.

She works on files that raise a wide range of domestic and international issues – namely, cross-border taxation, indirect taxes, trusts, valuation of businesses and real estate property, the general anti-avoidance rule and tax credits. She has acted for clients, appealing tax assessments before the Tax Court of Canada and the Court of Québec, in matters of judicial review before the Federal Court and the Superior Court of Québec, and before several other trial and appellate courts.

Clients turn to Élisabeth for her tenacious and detail-oriented approach to finding solutions to their litigation matters.

Élisabeth Robichaud

Partner

Élisabeth’s practice is focused on litigation and the settlement of tax disputes before tax authorities and the courts.

She works on files that raise a wide range of domestic and international issues – namely, cross-border taxation, indirect taxes, trusts, valuation of businesses and real estate property, the general anti-avoidance rule and tax credits. She has acted for clients, appealing tax assessments before the Tax Court of Canada and the Court of Québec, in matters of judicial review before the Federal Court and the Superior Court of Québec, and before several other trial and appellate courts.

Clients turn to Élisabeth for her tenacious and detail-oriented approach to finding solutions to their litigation matters.

Minority Stockholder

Acted for a minority stockholder of a private company in a buyout of the majority stockholder of that company by way of a cross-border acquisition of all the assets of that company through both equity and debt financing from a private equity firm and an institutional lender.

J.G. Guy Simard et al.

Acting for Colonel J.G. Guy Simard (retired) and other taxpayers who participated in the "Synergy Program", a program designed to provide funding for start-up businesses, in their dispute before the Tax Court of Canada with the Canada Revenue Agency over the deductibility of related losses. The appeals will serve as de facto representative cases for approximately 4000 other taxpayers who are contesting potentially over two hundred million dollars in tax deductions.

Bulletin

Federal Court of Appeal Says Funding Services Not Subject to GST/HST

Oct. 04, 2019 - In SLFI Group v Canada (2019 FCA 217), the Federal Court of Appeal (FCA) overturned a Tax Court of Canada (TCC) decision and ruled that a group of Canadian mutual funds (Funds) was not required to self-assess GST/HST on funding services provided by a U.S. entity, because these services...

Bulletin

Tax Fraud Charges: Jordan Stay of Proceedings Ordered Due to Unreasonable Delay

Sept. 04, 2019 - In a recent decision, the Court of Québec (Court) held that section 11b of the Canadian Charter of Rights and Freedoms, which guarantees that any person charged with an offence has the right to be tried within a reasonable time, had been infringed.1 It ordered a stay of proceedings in...

Bulletin

CRA’s Audit Powers Have Limits: Challenging Excessive Requests for Information

June 25, 2019 - In three recent decisions, the courts have curtailed the Canada Revenue Agency’s (CRA’s) broad interpretation of its audit powers and, in so doing, have armed taxpayers with the legal means to push back against excessive or unreasonable requests for information (RFIs) by the CRA. First, in...

Bulletin

The CRA Cannot Compel Oral Interviews During an Audit

Apr. 10, 2019 - In Minister of National Revenue v Cameco Corporation, the Federal Court of Appeal (FCA) dismissed the Minister of National Revenue’s appeal and held that the Canada Revenue Agency’s (CRA’s) audit powers under the Income Tax Act (ITA) do not extend to compelling taxpayers to be...

Bulletin

Callidus Capital Corporation v HMQ: Last Word Goes to the Secured Creditor

Nov. 14, 2018 - The Supreme Court of Canada (the SCC) has overturned the decision rendered by a majority of the Federal Court of Appeal (the FCA) in Callidus Capital Corporation v Her Majesty the Queen. The case originated out of a motion filed in the Federal Court (the FC) by Callidus Capital Corporation...

Article

FC's Surprise Rejection of CRA Data Request

Nov. 01, 2018 - Canadian Tax Focus, Vol. 8, No. 4 (Canadian Tax Foundation)
Reproduced here by permission of the Canadian Tax Foundation.
Read more about FC's Surprise Rejection of CRA Data Request.

Bar Admissions

Québec, 2011

Education

Université de Sherbrooke, Graduate Degree in the Prevention and Settlement of disputes, 2018
HEC Montréal, LLM (Tax), 2013
Université de Montréal, LLB, 2006

Professional Affiliations

Association de planification fiscale et financière
Canadian Tax Foundation

Board Memberships

MAI (Montréal, arts interculturels), secretary

Élisabeth’s practice is focused on litigation and the settlement of tax disputes before tax authorities and the courts.

She works on files that raise a wide range of domestic and international issues – namely, cross-border taxation, indirect taxes, trusts, valuation of businesses and real estate property, the general anti-avoidance rule and tax credits. She has acted for clients, appealing tax assessments before the Tax Court of Canada and the Court of Québec, in matters of judicial review before the Federal Court and the Superior Court of Québec, and before several other trial and appellate courts.

Clients turn to Élisabeth for her tenacious and detail-oriented approach to finding solutions to their litigation matters.

Minority Stockholder

Acted for a minority stockholder of a private company in a buyout of the majority stockholder of that company by way of a cross-border acquisition of all the assets of that company through both equity and debt financing from a private equity firm and an institutional lender.

J.G. Guy Simard et al.

Acting for Colonel J.G. Guy Simard (retired) and other taxpayers who participated in the "Synergy Program", a program designed to provide funding for start-up businesses, in their dispute before the Tax Court of Canada with the Canada Revenue Agency over the deductibility of related losses. The appeals will serve as de facto representative cases for approximately 4000 other taxpayers who are contesting potentially over two hundred million dollars in tax deductions.

Bulletin

Federal Court of Appeal Says Funding Services Not Subject to GST/HST

Oct. 04, 2019 - In SLFI Group v Canada (2019 FCA 217), the Federal Court of Appeal (FCA) overturned a Tax Court of Canada (TCC) decision and ruled that a group of Canadian mutual funds (Funds) was not required to self-assess GST/HST on funding services provided by a U.S. entity, because these services...

Bulletin

Tax Fraud Charges: Jordan Stay of Proceedings Ordered Due to Unreasonable Delay

Sept. 04, 2019 - In a recent decision, the Court of Québec (Court) held that section 11b of the Canadian Charter of Rights and Freedoms, which guarantees that any person charged with an offence has the right to be tried within a reasonable time, had been infringed.1 It ordered a stay of proceedings in...

Bulletin

CRA’s Audit Powers Have Limits: Challenging Excessive Requests for Information

June 25, 2019 - In three recent decisions, the courts have curtailed the Canada Revenue Agency’s (CRA’s) broad interpretation of its audit powers and, in so doing, have armed taxpayers with the legal means to push back against excessive or unreasonable requests for information (RFIs) by the CRA. First, in...

Bulletin

The CRA Cannot Compel Oral Interviews During an Audit

Apr. 10, 2019 - In Minister of National Revenue v Cameco Corporation, the Federal Court of Appeal (FCA) dismissed the Minister of National Revenue’s appeal and held that the Canada Revenue Agency’s (CRA’s) audit powers under the Income Tax Act (ITA) do not extend to compelling taxpayers to be...

Bulletin

Callidus Capital Corporation v HMQ: Last Word Goes to the Secured Creditor

Nov. 14, 2018 - The Supreme Court of Canada (the SCC) has overturned the decision rendered by a majority of the Federal Court of Appeal (the FCA) in Callidus Capital Corporation v Her Majesty the Queen. The case originated out of a motion filed in the Federal Court (the FC) by Callidus Capital Corporation...

Article

FC's Surprise Rejection of CRA Data Request

Nov. 01, 2018 - Canadian Tax Focus, Vol. 8, No. 4 (Canadian Tax Foundation)
Reproduced here by permission of the Canadian Tax Foundation.
Read more about FC's Surprise Rejection of CRA Data Request.

Bar Admissions

Québec, 2011

Education

Université de Sherbrooke, Graduate Degree in the Prevention and Settlement of disputes, 2018
HEC Montréal, LLM (Tax), 2013
Université de Montréal, LLB, 2006

Professional Affiliations

Association de planification fiscale et financière
Canadian Tax Foundation

Board Memberships

MAI (Montréal, arts interculturels), secretary