John Campbell practises taxation law, advising clients on domestic and international income tax issues. John has extensive experience with respect to the tax implications and structuring of corporate reorganizations, mergers and acquisitions, international tax planning, and other business transactions. He provides his clients with effective, practical tax advice based on his expertise and experience.
John also specializes in tax litigation. He has many years of experience representing clients in tax disputes with federal and provincial tax authorities, including proposed reassessments and notices of objection. He has appeared in the Tax Court of Canada, the Federal Court of Appeal, and the Ontario courts on tax appeals.
John has written extensively for various publications and spoken on numerous occasions at conferences on many different aspects of taxation law.
Professional achievements & leadership
- The Best Lawyers in Canada – Tax Law, 2019
- Canadian Legal Lexpert Directory, Estate & Personal Tax Planning, 2018
- Who’s Who Legal Canada: Private Client, 2015
- Lectures for the Canadian Tax Foundation, the Law Society of Ontario and other organizations on tax matters
- “Doing Business in Canada,” Invest in North America, September 2013
- “Insolvency Meets Tax: Debt Forgiveness and Restructuring,” Commons Institute, March 2012
- “International Taxation of Patent and Intellectual Property Licences,” European Patent Academy Seminar, May 2011
- “Tax Avoidance vs. Enforcement: Who is Winning?” Miller Thomson Seminar, June 2010
- “Tax Planning in Real Estate,” Canadian Institute of Chartered Accountants National Tax Conference 2010
- “Current Income Tax Cases – The Supreme Court of Canada’s GAAR Decisions,” CICA National Tax Conference 2005
- “Safe Income and Safe Income on Hand: An Update,” (with Greg C. Boehmer of Ernst & Young LLP) Ontario Tax Conference 2005
- “Canadian Income Tax Residence for Individuals,” STEP Canada National Conference 2002
- “Deductibility of Trips and Other Incentives for Independent Sales Contractors,” Direct Sellers Association Tax Seminar 2001
- “Income Tax Characterization of e-Commerce Revenues,” (with Douglas Han) Insight 2000
- “How to Obtain and Use Documents from the Canada Customs and Revenue Agency,” (with Robert Hayhoe) Ontario Certified General Accountants Public Practitioners Convention 2000
- “Access to Revenue Canada Documents,” Insight 1999, “Tax Issues on Going Public” – Infonex 1995
- “Recent Technical Interpretations and Administrative Developments,” Canadian Tax Foundation 1995 Ontario Tax Conference,
- “Taxation Aspects of Real Estate Remedies,” Lexium 1994
- “Recent Income Tax Cases,” Canadian Tax Foundation 1993 Ontario Tax Conference
- “Income Tax Assessments – Objections and Appeals,” Canadian Institute 1992
- “Starting U.S. Operations,” Canadian Tax Foundation 1991 Ontario Tax Conference.
- Case Review: The TDL Group Co. v. The Queen, Taxes & Wealth Management, Thomson Reuters, May 2015, Issue 8-2, 2015
- Canada’s Focus on International Tax, IFA Korea Journal, 2013
- Federal Budget Review, 2013
- Foreign Affiliate Dumping Transactions, International Tax Update, November 2012
- Pertinent Loan or Indebtedness Regime, International Tax Update, November 2012
- Thin Capitalization Regime, International Tax Update, November 2012
- International Tax Update – November 2012, Miller Thomson, 2012
- Upstream Loans and Other Indebtedness to Foreign Affiliates, Tax Notes, December 2011
- Foreign Exchange Gains and Losses, Tax Notes, Spring 2005
- New Draft Income Tax Legislation Respecting Non-Competition Covenants and Other Restrictive Covenants, Tax Notes, Summer 2004
- Ontario Capital Tax – Is Inventory Financing Exempt?, Tax Notes, Summer 2004
- Non-Resident Trust and Foreign Investment Entity Changes Postponed, Tax Notes, Winter 2002
- Cross Border Intercompany Management and Administration Charges, Tax Notes, Summer 2002
- Withholding Tax Exemption for Computer Software Royalties Broadened, Tax Notes, Spring 2002
- Employee Stock Options, Tax Notes, Winter 2001
- Tax Treaty Status Report, Tax Notes, Winter 2001
- Non-Resident Trusts – New Draft Legislation, Tax Notes, Fall 2001
- Employee Stock Options, Tax Notes, Spring 2001
- Tax Planning for the Private Company Shareholder on Death, Tax Notes, Spring 2001
- Non-Resident Trusts and Foreign Investment Entities, Tax Notes, Fall 2000
- Thin Capitalization Rules Tightened, Tax Notes, Spring 2000
- Canadian Bar Association
- Canadian Tax Foundation
- International Fiscal Association
Bar admissions & education
- Ontario Bar, 1983
- LL.B., University of Toronto, 1981
- B.A., University of Toronto, 1976
Miller Thomson lawyers recognized in The Best Lawyers in Canada 2019
In the just released 2019 edition of The Best Lawyers in Canada, 144 Miller Thomson lawyers from across the country have been recognized for their expertise in 47 areas of law. This includes 6 lawyers who were awarded “Lawyer of the Year” in...
Miller Thomson recognized in 2018 Canadian Legal Lexpert Directory
In the recently released 2018 edition of the Canadian Legal Lexpert® Directory, 90 Miller Thomson lawyers across 35 areas of law have been recognized for their industry-leading advisory expertise. These rankings are the culmination of an extensive annual peer review process...
John Campbell featured in Lexpert cover story, “Unsung Heroes of M&A”
The article, published in the June 2011 issue of Lexpert magazine, profiles several tax lawyers and the role they play in mergers & acquisitions. Read the article: “Unsung Heroes of M&A”
John Campbell and Maurice Fleming present “Insolvency Meets Tax: Debt Forgiveness and Restructuring” at the Expert Sessions on Bankruptcy Law Conference hosted by the Commons Institute.
John Campbell speaks at a European Patent Academy Seminar “Patents and Fiscal Modalities in Europe” on the topic of “International Taxation of Patent and Intellectual Property Licences”.
Complimentary Seminar for Accountants
Miller Thomson continues its tradition of holding semi-annual complimentary seminars for accountants. As in the past, our goal is to provide insight into timely tax and legal issues that interest you. Miller Thomson Lawyers present on the following topics: David...
Miller Thomson is hosting a Tax seminar in Vancouver on October 22, 2009
Topics discussed at this complimentary seminar are: Tax Litigation Update Debt Restructuring Techniques Loss Utilization Techniques ULC Problems and Solutions Limitation on Benefit Issues Commodities Tax Update Please click here for full details.
Case Review: The TDL Group Co. v. The Queen
Taxes & Wealth Management, Thomson Reuters, Issue 8-2, May 2015, 10-14
Canada’s Focus on International Tax
IFA Korea Journal
Federal Budget Review 2013
Click here to view.
Thin Capitalization Regime
IN THIS SECTION: Existing Canadian Thin Cap Regime Proposed Amendments to the Canadian Thin Cap Regime Reduction of Debt-to-Equity Ratio Extension of Canadian Thin Cap Regime to Loans from Specified Non-Residents to Partnerships Deemed Dividend Treatment for Canco’s Non-Deductible Interest...
Pertinent Loan or Indebtedness Regime
IN THIS SECTION: PLOI Relieving Rule for Subsection 15(2) Shareholder Indebtedness Scope of PLOI Exception PLOI Elections Certain Reorganizations Involving Canadian Resident Corporate Creditors Deemed Interest Income To File or Not to File a PLOI Election? Application Date PLOI Relieving...
Foreign Affiliate Dumping Transactions
IN THIS SECTION: Anti-Surplus Stripping Rule for Canadian Resident Corporations Controlled by Non-Residents What Canadian Resident Corporations Are Subject To Section 212.3? What Transactions Are Caught? Canadian Tax Consequences PUC Reduction under Subsection 212.3(7) Dividend Substitution Election PUC Reinstatement More...
International Tax Update
International Tax Newsletter
Click here to view the November 2012 issue.
Federal Budget Review
View the Federal Budget Review
Upstream Loans and Other Indebtedness to Foreign Affiliates
Draft legislation making significant changes to the foreign affiliate provisions of the Income Tax Act (Canada) (the “Act”) was released by the Department of Finance on August 19, 2011. The new provisions deal with upstream loans from and other indebtedness...
Foreign Exchange Gains and Losses
Crown Holdings completes acquisition of Signode Industrial Group Holdings
Canadian counsel to Crown Holdings, Inc.