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Robert B. Hayhoe

Robert B. Hayhoe

Partner
Toronto

416.595.8174
rhayhoe@millerthomson.com

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Profile

Robert Hayhoe's practice focuses on the voluntary sector. He provides both general counsel and specialized tax advice to charities and not-for-profit organizations across Canada, with a particular emphasis on religious charities.

Mr. Hayhoe advises clients on the tax law governing charitable registration. He is knowledgeable in the law relating to the receipt of gifts by registered charities as well as in the tax law dealing with expenditures by registered charities. He is experienced in dealing with the complex law governing foreign expenditures and activities by Canadian charities and in establishing structures to permit foreign charities to work and fundraise in Canada.

Mr. Hayhoe frequently represents charities and not-for-profit organizations faced with tax audits. He also represents charitable donors, as well as charities and their staff in Tax Court and Federal Court of Appeal matters involving tax compliance issues for charities and the tax treatment of charitable donations.

Mr. Hayhoe writes and speaks frequently on tax and charities issues. Dozens of his articles have been published in periodicals such as: The Lawyers Weekly, Canadian Tax Journal, International Journal of Not-for-Profit Law, and The Philanthropist and he is a co-author of the Charities Taxation: Policy and Practice textbook.

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Education

  • LL.M., Taxation, Osgoode Hall Law School, York University, 2000
  • In Depth Tax Course, Canadian Institute of Chartered Accountants, 2000
  • LL.B., University of British Columbia, 1995
  • B.A., Trinity College, University of Toronto, 1992

Professional Achievements

  • Recognized since 2004 in Canadian Legal Lexpert Directory as a leading Canadian Charities/Not-for-Profit Law practitioner
  • Leading Practitioner, Best Lawyers in Canada, Trusts and Estates (Charities/Not-for-Profit)
  • Recognized as a 2007 Rising Stars - Leading Lawyers Under 40

Directorships

  • Executive Member, Ontario Bar Association, Charities & Not-for-Profit Section

Memberships

  • Member, Ontario Bar Association, Taxation Section
  • Member, American Bar Association, Section of Taxation, Exempt Organizations Committee
  • Member, International Fiscal Association
  • Member, Canadian Tax Foundation
  • Member, Canadian Association of Gift Planners
  • Member, International Society for Third-Sector Research
  • Society of Trust and Estate Practitioners, TEP designation
  • Advisory Council Member: International Centre for Not-for-Profit Law

Presentations

Seminars

  • Budgets 2011 / 2012, in 10th National Symposium on Charity Law, Canadian Bar Association (Toronto), (May 2012)
  • Border Patrol Around the World: Private and Public Benefit in Canadian Charity Law, in Border Patrol: Charitable Status Despite Inurement or Private Benefit? New York University Law School National Center on Philanthropy and the Law, 23rd Annual Conference (New York), (October 2011)
  • Roundtable: Looking Ahead to the Biggest Legal Challenges, in The Intensive Short Course on Legal and Risk Management for Charities and NPOs Osgoode Hall Law School, York University (with T. Carter, E. Hofstein and D. Stevens) (Toronto), (October 2011)
  • Quiz the Whiz, Canadian Council of Christian Charities Annual Conference (with Justice P. Boyle, D. Amy and A. Miedema) (Toronto), (September 2011)
  • The New Canada Not-For-Profit Corporations Act ("CNCA"): Issues for Charities, Canadian Council of Christian Charities Annual Conference (with C. Goldfarb and B. Taylor) (Toronto), (September 2011)
  • Foundations, Society of Trusts and Estates Planners Annual Conference (Toronto), (June 2011)
  • 2011 Charities and Not-for-Profits Update, in 2011 Prairie Provinces Tax Conference, Canadian Tax Foundation (with Gail Black) (Edmonton), (May 2011)
  • Legal Update in Endowments, Foundations and Charities, Macquarie Private Wealth (Toronto), (May 2011)
  • Legal Update: Elimination of the 10-year rule: What are the implications for your organization? in 8th Annual Foundation, Endowment and Not For Profit Investment Summit, Strategy Institute (Toronto), (January 2011)
  • Fundraising Tax Law Refresher, Association of Fundraising Professionals Congress 2010 (with Kate Lazier) (Toronto), (November 2010)
  • Update on Tax Issues for Charities and Not-for-Profits, in 2010 Annual Tax Conference, Canadian Tax Foundation (with Amanda Stacey) (Vancouver), (November 2010)
  • Overview of the Taxation of Non-Profit Organizations, Canadian Society of Club Managers (Toronto), (November 2010)
  • Charities and Not-for-Profits: An Update, in 2010 Ontario Tax Conference, Canadian Tax Foundation (Toronto), (October 2010)
  • A Practical Approach to Working with US Charities, Canadian Council of Christian Charities Annual Conference (Winnipeg), (September 2010)
  • Audits and Appeals, in Critical Issues for Non-Profit Organizations, Pacific Business and Law Institute (Vancouver), (September 2010)
  • Canadian Cross Border Tax Issues, American Bar Association Tax Section Exempt Organizations Committee Fall Meeting, American Bar Association (Toronto), (September 2010)
  • The Ins and Outs of Audits and Appeals, in 8th National Symposium on Charity Law, Canadian Bar Association (Toronto), (April 2010)
  • Gifts in Kind, Canadian Association of Gift Planners Toronto Roundtable (with Geoff Berry) (Toronto), (April 2010)
  • CRA Charities Audits and Appeals, Thomson-Carswell webinar (Toronto), (March 2010)
  • Response to "A Canadian Culture of Generosity: Renewing Canada's Social Architecture by Investing in the Civic Core and the "Third Sector"" by Ray Pennings, Cardus (Ottawa), (September 2009)
  • A Proactive Approach to CRA Audits, Canadian Council of Christian Charities Annual Conference (with K. Lazier) (Toronto), (September 2009)
  • Carrying on Activities Outside of Canada: CRA's Proposed Guidelines for Charities, OBA Charity and Not-for-Profit Law Section (Toronto), (September 2009)
  • While You Were Away: Summer 2009 Developments (New Fundraising Guidelines for Charities, Foreign Activities Consultation and Recent Revocation Cases), OBA Taxation Law Section (Toronto), (September 2009)
  • New CRA Guidelines on Canadian Charities Operating Internationally, in Charities and Not-for-Profit Conference, Continuing Legal Education Society of British Columbia (with M. Trepanier) (Vancouver), (February 2009)
  • Canadian and US Ministries Working Together, Canadian Council of Christian Charities Annual Conference (with S.J. Lark) (Calgary), (September 2008)
  • The New Excess Business Holding Rules for Private Foundations: Practical Considerations in Advising Clients, in 6th National Symposium on Charity Law, Canadian Bar Association (Toronto), (April 2008)
  • Charities Update, Toronto Centre Canada Revenue Agency and Professionals Group Breakfast Seminar (with Gerry Hutcheon and Blaine Langdon) (Toronto), (November 2007)
  • CRA Charity Audits and Penalties, Lorman Education Services (Toronto), (October 2007)
  • Charity Audits and Intermediate Penalties, Lorman Education Services (Vancouver), (October 2007)
  • Canadian Tax Rules (and Other Legal Problems) for Foreign Mission Organizations, IFMA General Meeting (Minneapolis), (September 2007)
  • Gifts to Avoid, Canadian Council of Christian Charities Annual Conference (Toronto), (September 2007)
  • Effective Use of External Counsel, Canadian Council of Christian Charities Annual Conference (with Brian Campbell) (Toronto), (September 2007)
  • Foundations, Society of Trusts and Estates Planners Annual Conference (Toronto), (June 2007)
  • Difficult Gifts: Advising When (or How) NOT to Give a Gift, Society of Trusts and Estates Planners, Montreal Branch (with Arthur Drache), (May 2007)
  • Gifts of Residual Interests, Canadian Association of Gift Planners Annual Conference (with Linda Pearson) (Halifax), (April 2007)
  • Difficult Gifts: Advising Your Clients When (or How) Not to Give That Gift, Society of Trusts and Estates Planners, Toronto Branch, (February 2007)
  • Charities Update 2006, in 2006 Annual Tax Conference, Canadian Tax Foundation (Toronto), (November 2006)
  • Tax Update, Association of Fundraising Professionals Congress 2006 (with Susan Manwaring) (Toronto), (November 2006)
  • Advanced Governance Issues in Charities and Not-for-Profit Conference, Continuing Legal Education Society of British Columbia (Vancouver), (October 2006)
  • Legal Issues, Christian Camping International / Canada (Orford, Quebec), (November 2006)
  • CRA Charities Audits, Canadian Council of Christian Charities Annual Conference (with M. Loewen, D. Amy and Rheal Dorval) (Vancouver), (September 2006)
  • Directed Gifts, Canadian Council of Christian Charities Annual Conference (with Heather Card)(Vancouver), (September 2006)
  • Comparing the Ability of Canadian and American Charities to Operate and Fund Abroad – Tips on Foreign Activities by Canadian Charities, in 4th National Symposium on Charity Law, Canadian Bar Association (with P. Boyle, L. Woods and L. Mellon) (Toronto), (May 2006)
  • Obtaining (and Keeping) Charitable Status for Nonprofits, Volunteer Lawyer Service / City of Toronto, Community Services Unit (Toronto), (April 2006)
  • Recent Tax Changes Relating to Planned Giving, Canadian Association of Gift Planners Annual Conference (with Martin Rochwerg) (Calgary), (April 2006)
  • Obtaining and Maintaining your Charitable Status: Interpreting Where the Minefields Are, Ontario Seniors Secretariat (Toronto), (March 2006)
  • Gifts To Avoid, Canadian Association of Gift Planners (Toronto), (October 2005)
  • Legal Risks for Service Providers, Accreditation Ontario annual conference (Toronto), (October 2005)
  • Advancing Religion in the Public Square panel moderator, Canadian Council of Christian Charities / Christian Legal Fellowship Charities Day (Toronto), (September 2005)
  • Implementing Agency Agreements, Canadian Council of Christian Charities Annual Conference (with Lisa Mellon) (Toronto), (September 2005)
  • Joint Ministry Agreements, IFMA General Meeting (Minneapolis), (September 2005)
  • Disbursement Quota Compliance, Ontario Bar Association Charities Section (Toronto), (September 2005)
  • Permitted Advocacy and Prohibited Politics - Understanding the Distinction, 2005 Canadian Council for International Co-operation AGM (Ottawa), (May 2005)
  • Obtaining and Maintaining your Charitable Status: Interpreting Where the Minefields Are in McIninch Symposium on Charities and the Law, McIninch Foundation (Toronto), (May 2005)
  • Intermediate Sanctions: Lessons from the U.S. Experience, in 3rd National Symposium on Charity Law, Canadian Bar Association (with M.S. Owens) (Toronto), (May 2005)
  • Establishing Laws and Regulations that Support Planned Giving in Other Countries - Charitable Remainder Trusts in Canada in International Symposium on Cross-Border Charitable Giving, National Conference on Planned Giving (New York), (May 2005)
  • Legal Issues Surrounding New Vehicles – a gift planning refresher, Canadian Association of Gift Planners Annual Conference (Québec), (April 2005)
  • Advocating for Legal and Financial Integrity, in Advocating with Hope as Christians, Canadian Council of Christian Charities Relief and Development Group (Toronto), (October 2004)
  • Charities Update: 2004 Budget Proposals, in 2004 Ontario Tax Conference, Canadian Tax Foundation (Toronto), (October 2004)
  • CRA: Intermediate Sanctions and Compliance, Canadian Council of Christian Charities Annual Conference (Winnipeg), (September 2004)
  • Canadian and U.S. Ministry Relationships, Christian Management Association Annual Conference (with S.J. Lark) (Dallas, Texas), (April 2004)
  • Operating Outside of Canada: What’s New, What’s Right and What’s Wrong, in 2nd National Symposium on Charity Law “What’s New and What’s Coming,” Canadian Bar Association (Toronto), (April 2004)
  • Fundraising Across the 49th Parallel, Canadian Association of Gift Planners Annual Conference (Toronto), (April 2004)
  • Planned Giving for High Net Worth Individuals and Owner-Managers, BDO Dunwoody LLP National Tax Conference (Toronto), (January 2004)
  • Cross Border Charities Issues, Canadian Council of Christian Charities Annual Conference (Toronto), (September 2003)
  • Canadian and US Ministry Relationships, IFMA Administration Conference (with S.J. Lark) (Orlando), (May 2003)
  • Tax Issues and the CCRA in Charities & Not-for-Profit Lawyer: A Pot Pourri, Ontario Bar Association (Toronto), (October 2002)
  • Creating and Managing Charities, Non-profits and Foundations (with R. Kuhn) in Charities, Continuing Legal Education Society of British Columbia (Vancouver), (October 2002)
  • Dealing with CCRA in Charities, Continuing Legal Education Society of British Columbia (Vancouver), (October 2002)
  • Current Tax and Legal Developments, and “Introduction to Charity Law 101,” Canadian Council of Christian Charities Annual Conference (Calgary), (September 2002)
  • EHT Audits, Institute for Healthcare Financial Managers conference of the Ontario Hospital Association (with C. Tso) (Toronto), (September 2002)
  • Canadian Cross-Border Fundraising, Canadian Association of Gift Planners (with S.M. Manwaring) (Toronto), (October 2001)
  • How to Survive a CCRA Charities Audit, Canadian Council of Christian Charities Annual Conference (Toronto), (September 2001)
  • An Introduction to the Taxation of Non-Profit Organizations, in The ABC’s of NPO’s: Getting Oriented in the World of “Not-For-Profit,” Canadian Bar Association – Ontario (Toronto), (May 2001)
  • Introduction to Gift Planning, Canadian Bar Association – Ontario Volunteer Lawyer Program (with J. Sweatman and L. Pearson) (Toronto), (April 2001)
  • How to Survive a CCRA Charity Audit, Canadian Council of Christian Charities Annual Conference (Vancouver), (September 2000)
  • Income Tax Objections and Appeals, Certified General Accountants Association of Ontario (London), (September 2000)
  • Business Law - Tax, Law Society of Upper Canada Bar Admission Course (Toronto), (December 1999)

Academic Lectures

  • Audits, Sanctions and Appeals, in CML 4104 Studies in Public Law: Introduction to the Law of Charities and Non-Profit Organizations, University of Ottawa Law School course (with P. Picard and K. Cooper) (Ottawa), (November 2009)
  • Audits, Sanctions and Appeals, in CML 4104 Studies in Public Law: Introduction to the Law of Charities and Non-Profit Organizations, University of Ottawa Law School course (with G. Landry and K. Cooper) (Ottawa), (November 2008)
  • Canadian Tax Treatment of the Voluntary Sector, in Landscape of Mexican Civil Society, Instituto Tecnológico y de Estudios Superiores de Monterrey, Campus Ciudad de México (with Prof. A. Hernández Baqueiro) (Mexico), (Winter 2008)
  • Audits, Sanctions and Appeals, in CML 4104 Studies in Public Law: Introduction to the Law of Charities and Non-Profit Organizations, University of Ottawa Law School course (with G. Landry and K. Cooper) (Ottawa), (November 2007)
  • International Philanthropy, in MPA 880 Operational, Policy and Legal Issues in the Third Sector, Queens University School of Policy Studies MPA course (with A. Drache) (Kingston), (May 2007)
  • International Philanthropy, in MPA 880 Operational, Policy and Legal Issues in the Third Sector, Queens University School of Policy Studies MPA course (with A. Drache) (Kingston)., (May 2005)
  • Business Law, Canadian School of Management MBA course (with S. Georgas) (Toronto), (Winter 1999)

Publications

  • Charities Taxation, Policy and Practice (Toronto: Thomson-Carswell, 2007-present looseleaf)
  • Recent cases on charity law issues, Charity Talk, (November 2011)
  • 2011 federal budget: Provisions regarding charities and other qualified donees, Charity Talk, (May 2011)
  • 2010 Update on Tax Issues for Charities and Not-for-Profits, Report of Proceedings of Sixty-second Tax Conference. 2010 Conference Report (Toronto: Canadian Tax Foundation), (2011)
  • Bad Behaviour, STEP Journal, (2011)
  • Breaking Down the Borders - Operating Charitable or Tax Exempt Organizations Across the Canada/US Border in The Canadian Legal Lexpert Directory 2011, 15th ed. (Toronto: Lexpert, Thomson Reuters Canada Ltd.), A-50 - A-53, (2011)
  • Budget includes anti-abuse tax rules for charities, 31:8 Lawyers Weekly 17, (2011)
  • Canada: recent legal developments affecting private foundations, 17:6 Trusts and Trustees 508, (2011)
  • CRA High Net Worth Audit Program, 30:45 Lawyers Weekly 13, (2011)
  • Restrictive New Canadian Test for Non-Charitable Nonprofits, 67:6 Exempt Organization Tax Review 571, (2011)
  • Transcript of the September 24, 2010 ABA Tax Section Exempt Organizations Committee Meeting, 66 Exempt Organizations Tax Review 567 at 606, (2011)
  • Turf tussle erupts in charity over fiduciary duty, 31:29 Lawyers Weekly 10, (2011)
  • When Should a Charity Indemnify Directors, 19:3 Canadian Not-for-Profit News 21, (2011)
  • A Sketch of the Income Tax Act Treatment of Endowments, 23:1 The Philanthropist 93, (2010)
  • Canada: private foundations and international activities, 16:6 Trusts and Trustees 430, (2010)
  • CRA Attempts to Narrow Non-Profit Tax Exemption, 29:40 Lawyers Weekly, (2010)
  • Osgoode's Professional LL.M in Charity and Not-for-Profit Law, 14:1 Charitable Thoughts, (2010)
  • Tax Shelter Promoter Faces Civil Liability, 30:8 Lawyers Weekly, (2010)
  • The Obligation of a Charity to Indemnify Directors, 30:29 Lawyers Weekly 13, (2010)
  • Canada: recent developments for private foundations, 10 Trusts and Trustees 44, (2009)
  • Canadian Charities Participating in Business Activities, 64 Exempt Organization Tax Review 477, (2009)
  • CRA Not Required to Honour Charity Compliance Agreements, 29:8 Lawyers Weekly 16, (2009)
  • Charity Rules, 16:9 STEP Journal 43, (2008)
  • Charity Suspension Postponements Unavailable?, 56:1, Canadian Tax Journal 167, (2008)
  • Public Benefit and Canadian Public Hospitals, 59:2 Exempt Organization Tax Review 149, (2008)
  • The Continuing Saga of Charitable Donation Tax Shelters in Canada, 61:2, Exempt Organization Tax Review 159, (2008)
  • Charities must maintain control of activities undertaken abroad, 27:26 Lawyers Weekly 8, (2007)
  • Canada Revenue Agency Notes, 12:1 Charitable Thoughts, (2007)
  • Charities Update, Report of Proceedings of Fifty-Eighth Tax Conference. 2006 Conference Report (Toronto: Canadian Tax Foundation), (2007)
  • Give and Take, 15:8 STEP Journal 18, (2007)
  • Quebec Changes Tax Treatment Of Clergy, 29:4 Canadian Taxpayer 29, (2007)
  • The 2007 Canadian Federal Budget – Implications for Charities, 56:2 Exempt Organization Tax Review, (2007)
  • There are times when not doing a gift is the better choice, 17:18 Canadian Fundraiser 53, (2007)
  • Canada-U.S. Boundary Issues for Cross-Border Charitable Activities, The Taxation of Exempts 129, (November-December 2006)
  • Avoid Temptation to Invest in Limited Partnerships, Canadian Fundraiser, (July 31, 2006)
  • 2006 Federal Budget Changes for Charities, The Advisor, (2006)
  • 2006 Federal Budget Changes for Charities, 9:5 Charitable Thoughts, (2006)
  • Canada Revenue Agency Audits and Record-Keeping, 51:3 Exempt Organization Tax Review 237, (2006)
  • CRA Now Accepts Gifts to U.S. Religious Schools, 14:1 Canadian Not for Profit News, (2006)
  • CRA Now Accepts Gifts to U.S. Religious Schools, 28:3 The Canadian Taxpayer 20, (2006)
  • Federal Court Reviews CRA Undertaking Letter, 14:2 Canadian Not for Profit News 13, (2006)
  • For-Profit Philanthropy, 14:11 Canadian Not for Profit News 85, (2006)
  • Limited Partnership Investment by Charities, 14:8 Canadian Not for Profit News 61, (2006)
  • The Clergy Residence Deduction Case: Denominational Appointments and Cross-Appointments, 1 Canadian Council of Christian Charities Bulletin 15, (2006)
  • The New Tax Sanctions for Canadian Charities: Learning from the U.S. Experience, 54:1 Canadian Tax Journal 57, (2006)
  • Canadian Taxation of Charities and Donations (Toronto: Thomson-Carswell, 2004-2006 loose leaf)
  • Finance abandons proposed due diligence requirement for charities receiving large gifts, Lawyers Weekly, (December 9, 2005)
  • Basic Canadian Donation Tax Law in Your Guide to Charitable Giving & Estate Planning, Canadian Association of Gift Planners Leave A Legacy Magazine Greater Toronto Area: Globe & Mail, (May 5, 2005)
  • Helpful New CRA Policy on Foreign Activities by Canadian Charities, Canadian Council of Christian Charities Bulletin 3, (March 2005)
  • Commentary: On Tax Rules for Registered Charities Outside Canada, 24:34 Lawyers Weekly 18, (2005)
  • Federal legislation creates new diligence requirements for charities, 25:16 Lawyers Weekly 10, (2005)
  • Gifts to U.S. Religious Schools, 13:10 Canadian Not-For-Profit News 77, (2005)
  • Modern Canadian Federal Not-For-Profit Statute Introduced, 47:2 Exempt Organization Tax Review 177, (2005)
  • New Compliance Obligations for Charities Issuing Large Receipts, 9:2 Charitable Thoughts, (2005)
  • New Compliance Obligations for Charities Issuing Large Receipts, The Advisor, (Fall 2005)
  • Proposed New Uniform Charitable Fundraising Act May Harmonize Fundraising Licensing Across Canada, 50:1 Exempt Organization Tax Review 33, (2005)
  • U.S. Governance Reform Proposals, 13:4 Canadian Not-For-Profit News 27, (2005)
  • Update on Canadian Charities Operating Abroad, 48:3 Exempt Organization Tax Review 295, (2005)
  • An Introduction to the Canadian Tax Treatment of the Third Sector, 6:2 International Journal of Not-for-Profit Law, (2004)
  • An Updated Introduction to the Taxation of Non-Profit Organizations, 18 The Philanthropist 91, (2004)
  • Are Grants to U.S. Charities Permitted by Canada-U.S. Tax Treaty?, 12:9 Canadian Not-for-Profit News 67, (2004)
  • Budget Amends Revocation and Annulment of Registration Rules and Increases Information Disclosure, 7:4 Charitable Thoughts, (2004)
  • Canadian Federal Budget Increases Transparency for Charities, 6:3 International Journal of Not-for-Profit Law, (2004)
  • Canadian Federal Budget Introduces Intermediate Sanctions, 44:2 Exempt Organization Tax Review 185, (2004)
  • CCRA Shuts Down Charitable Donation Tax Shelters, 23:36 Lawyers Weekly 9, (2004)
  • Charities Update: 2004 Budget Proposals, Report of Proceedings of Fifty-Sixth Tax Conference, 2004 Conference Report (Toronto: Canadian Tax Foundation, 8:1), (2004)
  • Comparing the Ability of Canadian and U.S. Charities To Fund and Operate Abroad, 46:2 Exempt Organization Tax Review 201, (2004)
  • Cross-Border Operations by Canadian Registered Charities, 52:3 Canadian Tax Journal 941, (2004)
  • Highlights of the 2004 federal budget as it affects charities, 23:46 Lawyers Weekly 9, (2004)
  • Recent Developments in Charities / Not-for-Profit Law, 2004 Canadian Legal Lexpert Directory, (2004)
  • Tax Treaty Legal Argument Permitting Canadian Charities to Make Grants to U.S. Charities, 45:2 Exempt Organization Tax Review 241, (2004)
  • TCC rejects retail value for charitable art donation, 23:41 Lawyers Weekly 16, (2004)
  • The End of Charitable Donation Tax Shelters in Canada?, 34:5 Tax Notes International 517, (2004)
  • The End of Charitable Donation Tax Shelters in Canada?, 44:1 Exempt Organization Tax Review 69, (2004)
  • Ways for Canadian charities to be involved internationally, 24:10 Lawyers Weekly 17, (2004)
  • Canada Customs and Revenue Agency Charities Audits, 17 The Philanthropist 38, (2003)
  • CCRA Audits – I: Everything you ever wanted to know but were afraid to ask, 13:19 Canadian Fundraiser 8, (2003)
  • CCRA Audits – II: A charity’s responsibilities, privileges, faced with an audit, 13:20 Canadian Fundraiser 11, (2003)
  • CCRA Audits – III: How it works: cost of non-compliance may be de-registration, 13:21 Canadian Fundraiser 11, (2003)
  • CCRA Audits – IV: Current issues: advocacy, foreign activities, terrorism, 13:22 Canadian Fundraiser 12, (2003)
  • CCRA Audits – V: Some stumbling blocks which may get charities in trouble, 13:23 Canadian Fundraiser 12, (2003)
  • CCRA Policy on Volunteer Expenses, 1:3 International Journal of Civil Society Law 158, (2003)
  • Current CCRA Issues, 6:1 Charitable Thoughts 7, (2003)
  • December Tax Changes for Charities, 19:3 The Bottom Line 10, (2003)
  • Draft technical bill makes several changes regarding charities, 22:36 Lawyers Weekly 9, (2003)
  • Federal Report Recommends Changes to the Regulation of Charities, 19:8 The Bottom Line 9, (2003)
  • Federal Report Recommends Changes to the Regulation of Charities, 23:8 Lawyers Weekly 9, (2003)
  • New CCRA Social Housing Policy is More Flexible, 23:19 Lawyers Weekly 15, (2003)
  • Planned Giving Provides Benefits for Charities and Donors Alike, CIBC Global Private Banking and Trust Masters Series, (2003)
  • Canada Country Update: Charities Registration (Security Information) Act, 4:2-3 International Journal of Not-for-Profit Law, (2002)
  • Canada Country Update: New Proposals for Federal Charities Regulation, 5:1 International Journal of Not-for-Profit Law, (2002)
  • Canada Country Update: Reform of the Canada Corporations Act, 4:4 International Journal of Not-for-Profit Law, (2002)
  • Case Comment on Canadian Magen David Adom for Israel v. The Queen, 5:1 International Journal of Not-for-Profit Law, (2002)
  • Case Comment on Canadian Committee for the Tel Aviv Foundation v. Canada, 4:4 International Journal of Not-for-Profit Law, (2002)
  • Federal Report Recommends Changes to the Regulation of Charities, 22:18 Lawyers Weekly 9, (2002)
  • Keeping records key for Canadian charities using foreign agents, 22:7 The Lawyer’s Weekly 9, (2002)
  • Large Gifts Resulting in Private Foundation Status, Canadian Council of Christian Charities Bulletin, (2002)
  • Position Summary Canadian Bar Association Charity & Not-For-Profit Law Section, 17 The Philanthropist 57, (2002)
  • A Critical Description of the Canadian Tax Treatment of Cross-border Charitable Giving and Activities, 49 Canadian Tax Journal 320, (2001)
  • Can U.S. Nonprofits Raise Funds in Canada?, 19:1 Nonprofit World 6, (2001)
  • Complex Rules for Charities with Foreign Activities, 20:45 The Lawyer’s Weekly 12, (2001)
  • Large Gifts Resulting in Private Foundation Status, 5:1 Charitable Thoughts 7, (2001)
  • Withholding Tax on the Elvis Stojko Show, 4:4 Canadian International Lawyer 214, (2001)
  • Fundraising from Canada (United Kingdom: Chapel & York, 2001)
  • Foreign Charities Fundraising in Canada, Associates Alert (U.K.), (2000)
  • The Interpretation of Religious Terms in the Courts: The Clergy Housing Deduction, 3 Journal of the Church Law Association of Canada 164, (2000)
  • Clergy Housing in Canada's Tax Court, Christian Legal Journal 17, (Spring 1999)
  • Obtaining Revenue Canada Documents (Toronto: Insight Press), (1999)
  • Fraud, the Consumer and the Banks: the (Un-)Regulation of Electronic Funds Transfer, 53 U. T. Fac. L. Rev. 346, (1995)

Industry Expertise

Key Practice Expertise

Areas of Focus

  • CRA Audits
  • Religious Charities
  • Foreign Charities

Year of Call

  • Ontario Bar, 1998
  • British Columbia Bar, 2006