Laurie A. Goldbach  


Executive Summary

Laurie's practice focuses on tax litigation and tax dispute resolution, from the audit and objection stages to tax appeals before the courts. She regularly assists clients in resolving tax disputes, both in and out of Court, and engages in managing complex tax audits, ensuring that the tax authorities operate within the lawful parameters regarding demands for information and documents and correcting non-compliance issues. Laurie has completed the CPA Canada In-Depth Tax Course.

Laurie has extensive trial and appellate advocacy experience and regularly appears before all levels of courts in Alberta, and has appeared before the Tax Court of Canada, the Federal Court of Canada and the Supreme Court of Canada. Laurie has also practised as a commercial litigator with a focus on oil and gas and regulatory litigation.

Representative Work

  • Acting as lead counsel for corporate and individual taxpayers before the Tax Court of Canada.
  • Advising taxpayers undergoing large and complex audits.
  • Representing corporate taxpayers in respect of sales tax and other commodity tax disputes.
  • Pursuing judicial reviews in connection with the actions of taxing authorities.
  • Obtaining rectification and related equitable remedies in relation to transactions with unintended tax consequences.
  • Assisting clients with voluntary disclosures under the Canada Revenue Agency’s Voluntary Disclosure Program.
  • Lead counsel to a number of well servicing contractors in a long-standing industry-wide dispute involving the applicability of provincial sales tax: Burlington Resources Ltd. v. British Columbia, 2013 BCSC 292; 2015 BCCA 19.
  • Appellate counsel to taxpayers in connection with the common law treatment of gifts: Neville v. National Foundation for Christian Leadership, 2014 BCCA 38.
  • Lead trial counsel in a successful multi-week trial to a number of well servicing contractors in a long-standing industry-wide dispute involving the applicability of provincial sales tax: R v. Husky Oil Operations Limited, 2014 SKQB 116.
  • Appellate counsel to a major power company in its successful appeal relating to a taxpayer’s right to allocate sale proceeds between asset classes on the sale of a business: Transalta Corporation v. Canada, 2012 FCA 20.
  • Appellate counsel to an estate in connection with a successful appeal from reassessment by the CRA which disallowed charitable tax credits in respect of donation of two promissory notes to a charitable foundation and related GAAR claims:  Canada v. Remai, 2009 FCA 340.
  • Appellate counsel to an individual charged under the tax evasion provisions of the Income Tax Act (Canada): R v. Breakell, 2009 ABCA 350.
  • Appellate counsel in connection with a precedent setting case regarding the ability to seek relief for unfair treatment by the CRA under section 160 of the Income Tax Act (Canada): Canada v. Addison & Leyen Ltd., 2007 SCC 33.
  • Trial and appellate counsel to a number of petroleum producers in Alberta and in Inuvik in the successful interpretation of a production licensed issued under the Canada Petroleum Resources Act and the assessment of royalty taxes payable to the Crown under it: AltaGas Marketing Inc. et al v. Her Majesty the Queen, 2007 FC 1234.
  • Trial counsel in a lengthy trial to a major Canadian resource company in the successful defence to a multi-million dollar contractual claim involving a SAGD prospect: IFP Technologies (Canada) v. Encana Midstream and Marketing, 2014 ABQB 470.
  • Trial counsel to a North American pipeline company in successfully defending a challenge to title to its pipeline: Joarcam LLC v. Plains Midstream Canada, 2012 ABQB.
  • Appellate counsel to a major natural gas pipeline company in successfully defeating a challenge to the integration of regulated gas transmission services in Alberta: ATCO Gas and Pipelines Ltd. v. Alberta (Energy and Utilities Board), 2012 ABCA 16.
  • Appellate counsel to a major gas and electric utility in its appeal from the Alberta Energy and Utilities Board Order purporting to require it to hold the proceeds of an asset in a deferral account.  The successful appeal confirms that the Regulator has no jurisdiction over utility assets not required to provide utility service and that the utility is entitled to the sale proceeds without any conditions: ATCO Gas and Pipelines Ltd. v. Alberta (Energy and Utilities Board), 2009 ABCA 171, [2009] SCCA No. 309.
  • Appellate counsel to a major utility in its successful appeals of three related decisions regarding the ability of its Regulator to assert jurisdiction over its carbon gas storage facilities and related production properties, which assets no longer serve any purpose for utility service.  Significantly, the Court ruled that revenue generation is not a valid utility service: ATCO Gas and Pipelines LTD. v. Alberta (Energy and Utilities Board), 2008 ABCA 200, [2008] SCCA No. 347.
  • Appellate counsel to a major utility in connection with the Supreme Court of Canada’s landmark decision affirming its property rights: ATCO Gas and Pipelines Ltd. v. Alberta Energy and Utilities Board, 2006 SCC 4.

Publications & Presentations

  • Speaker, “Protecting Privilege,” Canadian Tax Foundation Calgary Young Practitioners Group, December 13, 2018
  • Author, “CRA’s Power to Compel Taxpayers to Disclose Uncertain Tax Positions Affirmed,“ BLG Bulletin, November 14, 2018 
  • Speaker and Author, "Protecting Privilege," 2018 British Columbia Tax Conference and Live Webcast, September 2018
  • Speaker, "Selected Tax Issues – An Update on Rectification: What is Left?", Tax Executive Institute, Vancouver, April 2018
  • Speaker, "Tax Advantaged Financing Structures", BLG Calgary Breakfast Seminar, April 2018
  • Author, "Supreme Court of Canada to Rule on CRA Superpriorities – Canada v. Callidus Capital Corporation", BLG Bulletin, April 6, 2018
  • Author, "Federal Court of Appeal Reaffirms the Validity of Transactional Common Interest Privilege – Iggllis Holdings Inc. v. Canada (MNR), BLG Bulletin, March 15, 2018
  • Speaker, "Case Law Update", Society of Trust and Estate Practitioners, Calgary, January 2018
  • Author, "Don't Delay; Disclose Today: Substantial Changes to the Voluntary Disclosure Program Take Effect March 1, 2018", BLG Bulletin, January 11, 2018
  • Author, "Alberta Court of Appeal Denies Equitable "Hail Mary" in Harvest Operations Corp. v. AG (Canada), BLG Bulletin, December 18, 2017
  • Speaker, "Transfer Pricing and Dispute Resolution: Landscape and Trends," Tax Executive Institute, Calgary, 2017
  • Speaker, "Rectification Following Fairmont and Coutu," National Presentation to Deloitte LLP, 2017
  • Speaker and Author, “Tax Disputes and Litigation: Tips and Traps for Tax Planners,” 68th Annual Tax Conference, CTF (2016 presentation; 2017 publication)
  • Speaker, “Tax Controversy Update: Caselaw, Trends and Traps,” Canadian Petroleum Tax Society, Annual Conference (2015)
  • Speaker, “Canadian Tax Dispute Resolution and Litigation”, Deloitte Global Tax Transfer Pricing and International Tax Roundtable, Orlando (2014)
  • Author, “Rectification Update”, Canadian Petroleum Tax Society, Calgary (2014)

Rankings & Recognitions

  • Recognized twice by Legal Media Group's - Benchmark Canada as a “litigation future star”.
  • Highlighted in the International Tax Review's Women in Tax Leaders Guide.
  • Recognized as a Tax Controversy Leader by International Tax Review.