Bobby Solhi

Bobby B. Solhi  


Executive Summary

Bobby Solhi is partner in BLG's Tax Group. His practice is focused on the GST/HST and commodity taxes as well as tax planning for privately held companies and their owners. He regularly provides tax advice to Canadian and foreign clients on business transactions including new ownership structures, re-organizations, mergers, acquisitions, and divestures across various industries.

Bobby has a very active tax litigation and dispute resolution practice where he represents clients in tax disputes with tax authorities. He has appeared before the Tax Court of Canada and Federal Court of Appeal with the vast majority of cases settled favourably prior to a hearing.

During his time at Ministry of Finance, Bobby was a key contributor to several high-profile projects in tax administration, tax policy design, and the introduction of the HST in Ontario.

Representative Work

  • Advised on tax aspects of renewal energy projects
  • Advised on tax aspects of a multi-billion-dollar class action settlement
  • Advised on tax structuring of several multi-unit real property developments
  • Advised on tax residency for many foreign clients with Canadian business activities
  • Advised multi-national chemical supplier on tax implications of interprovincial sales
  • Advised multi-national technology firms on tax implications of cross-border technology service/SAS arrangement
  • Acted for foreign technology companies with tax aspects of inbound transactions
  • Acted for automotive suppliers on tax implications of exports and outbound transactions
  • Acted for wholesalers of tobacco products in significant tax dispute
  • Advised on and implemented various tax purification and reorganization transactions
  • Represented various individual and corporate clients in tax disputes at the Tax Court level.

Select Tax Cases

  • Rybakov, et al. v. Her Majesty the Queen (2018-4469(GST)G)
  • Lohas Farm Inc. v. Her Majesty the Queen (2016-961(GST)G)
  • Kniazev v. Her Majesty the Queen (2019 TCC 58)
  • 2253787 Ontario Inc. v Her Majesty The Queen (2014 TCC 121)
  • 2266504 Ontario Inc. v Her Majesty The Queen
  • Faisal Javaid v. Her Majesty The Queen (2015 TCC 94)
  • Garipov v. Her Majesty The Queen (2015-2110 (GST)I)
  • Garipov v. Her Majesty The Queen (2015-2106 (GST)I)
  • Ranjbar v. Canada (2016 FCA 116)

Publications & Presentations

Mr. Solhi is a regular contributor to several industry-leading publications. Bobby is a featured Canadian tax law expert for LexisNexis’ Legal Practice Advisor publication where he writes extensively and has developed practical modules on tax law for lawyers involved in corporate and commercial transactions.

Bobby was also a board member and contributing editor to Sales and Use Tax, a quarterly journal published by Thomson Reuters devoted to Canadian commodity tax developments, including the GST, excise taxes and provincial sales taxes.

Select publications include:

  • GST/HST on Exports from Canada: Ships, Carriers, and Place of Delivery,” Canadian Tax Foundation (CTF), Tax for the Owner Manager, April 2019.
  • "Miedzi v. The Queen: Revisit of ITCs claimed “in relation to” a Subsidiary," Ferated Press, Sales and Use Tax Journal, November 2015.
  • “CRA Reneges on Longstanding Assessment Agreement.” Canadian Tax Foundation (CTF), Tax for the Owner Manager, April 2015.
  • “Recent Cases on Directors’ Liability,”Canadian Tax Foundation (CTF), Tax for the Owner Manager, October 2014.
  • “Loss on Securities: Income or Capital,”  Canadian Tax Foundation (CTF), Tax for the Owner Manager.
  • “Provincial Income Tax: What is the Province of Residence?,” Ontario Bar Association, Taxation Section Newsletter.
  • “Sale of a New-ish Home: GST/HST and the Self Supply Rules”, Privately Held Companies & Taxes, Carswell, TaxNetPro, September 2012.
  • “Lifetime Capital Gains Exemption Allowed Despite Errors,” Ontario Bar Association, Taxation Section Newsletter.
  • “Input Tax Credit for Holding Companies: Subsection 186(1)," Privately Held Companies & Taxes, Carswell, TaxNetPro, December 2012.

Bobby frequently presents on tax law matters before accounting and financial organizations and is occasionally sought out to comment on developments in Canadian tax law to outlets such as Tax Notes, Bloomberg BNA International Tax Monitor, Blacklock’s, and CBC News.

Rankings & Recognitions

  • Certificate of Achievement, Chartered Professional Accountants ("CPA") Canada
  • Honourable Paul I.B. and Mrs. Tevis Staniszewski Award
  • Millennium Excellence Scholarship