Salvatore Mirandola

Salvatore Mirandola  

Partner

Executive Summary

Salvatore (Sal) Mirandola is a partner in the Toronto office of Borden Ladner Gervais LLP. Sal devotes the bulk of his practice to tax dispute resolution, representing corporate and individual taxpayers before various courts and tax administrative bodies in respect of federal and provincial tax matters. He advises and represents clients at all stages of the tax dispute resolution process, from audit to appeal.

Sal also has extensive experience in making submissions to tax authorities in respect of voluntary disclosures and requests for taxpayer relief (e.g., waivers of interest and/or penalties), and in obtaining judicial rectification orders.

Other areas of practice include advising clients on commodity tax matters (e.g., HST/GST, land transfer tax) and employer tax compliance matters (e.g., source deductions) in the context of potential disputes with the tax authorities.

Representative Work

  • Representing numerous corporate and individual taxpayers (resident and non-resident) before Canada's tax courts.
  • Obtaining rectification orders from Ontario's superior court.
  • Making numerous voluntary disclosures on behalf of Canadian and non-resident taxpayers involving several types of tax.
  • Advising taxpayers in respect of Ontario sales tax and GST/HST compliance and dispute resolution matters.
  • Negotiating settlements of tax disputes with officials of various tax authorities and with counsel at the Department of Justice and counsel at the Legal Services Branch of the Ontario Ministry of Revenue.

Cases

Publications & Presentations

Frequent speaker to tax professionals, corporate tax officers, and tax authorities on many topics relevant to the resolution of tax disputes, including solicitor-client privilege issues, rectification, voluntary disclosures, document production and retention, and settlement of tax disputes.

Rankings & Recognitions

  • Recognized in the 2016 edition of ITR World Tax.