Deloitte Legal Canada LLP

Tax Litigation

Partner

Mike Collinge is the Leader of the Tax Litigation and Controversy Practice for the Ontario Region of Deloitte Legal Canada LLP. His practice is primarily focused on tax litigation and tax controversy. He was admitted to the Law Society of Ontario in 2012 after receiving his Juris Doctor from the University of Toronto Faculty of Law and completing a clerkship at the Tax Court of Canada.

Mike has successfully represented clients in a wide variety of domestic and international tax disputes involving the Canada Revenue Agency and the provincial tax authorities, and in litigation proceedings in the Tax Court of Canada, the Federal Court and the Federal Court of Appeal. Mike regularly assists clients by filing notices of objection with the tax authorities, responding to complex audits, and conducting court proceedings to dispute tax assessments. Representative recent engagements include the following:

Successful resolution of a Tax Court appeal involving reassessments totaling approximately $550 million that were issued to a Fortune Global 500 company in connection with a share valuation issue. Successful application for judicial review to challenge a decision by the CRA denying the retroactive revocation of an election by a major Canadian insurance company. Successful Tax Court appeal involving the existence of a partnership that was created by a member of the S&P/TSX 60. Successful resolution of notices of objection to dispute reassessments totaling approximately $150 million that were issued to a Fortune Global 500 company on the basis that an instrument should be characterized as equity rather than debt. Currently representing a venture capital company in a Tax Court appeal involving the application of the GAAR to a so-called “loss trading” transaction. Currently assisting an offshore trust that has filed notices of objection to dispute reassessments that were issued in connection with a residency issue.

Memberships and Professional Affiliations

Canadian Tax Foundation The Advocates’ Society

Education

University of Toronto Faculty of Law: J.D. (2011) University of Victoria: B.A. (Hons.) (2005, with distinction) Chartered Professional Accountants of Canada (CPA) In-Depth Tax Course, Parts I, II and III