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Genevieve Lille

Geneviève Lille

Counsel
Toronto
About

Geneviève advises Canadian domestic and multinational clients on all aspects of Canadian corporate tax, including mergers and acquisitions, financings, corporate reorganizations and investment structures.

Geneviève‎ is highly regarded for her expertise in the area of Canadian partnership taxation. She is co-author of Canada’s only book dedicated to the taxation of partnerships, Understanding the Taxation of Partnerships (Wolters Kluwer) and is Adjunct Professor at Osgoode Hall’s Professional Tax LLM Program, where she teaches Taxation of ‎Partnerships and Tax Shelters.‎

Geneviève also assists clients in their dealings with the Canadian federal and provincial tax authorities.

Geneviève is a frequent speaker on taxation matters and an author and contributor to various tax publications. She is a recipient of the Canadian Tax Foundation's Douglas J. Sherbaniuk Distinguished Writing Award.

Areas of FocusTaxTax Controversy and DisputesInternational Tax and StructuringTransactional Tax
Bar admissionsOntario, 2001Québec, 1999
Languages
  • English
  • French
Education
  • LLM, Osgoode Law School, 2009‎
  • LL.B., and B.C.L, McGill University, ‎‎1998‎

Awards

  • International Tax Review, World Tax Leaders, 2023
  • Canadian Legal Lexpert Directory (Corporate Tax), 2023
  • Canadian Tax Foundation's Douglas J. Sherbaniuk Distinguished Writing Award

Publications

  • Author, “Current Cases—A New Spin on Deductibility of Stock Option Surrender Payments,” Corporate Finance, 2018 Vol. XXI, No. 4
  • Author, “The Slow Demise of the Enduring Benefit Test and the Rise of Underlying Purpose,”‎ Corporate Finance, 2018 Vol. XXI, No. 3
  • Co-author, Understanding the Taxation of Partnerships, 7th edition, Wolters Kluwer, 2017, (Also co-author of the 6th edition published in 2010)‎
  • Co-author, "Partnerships: An Update," Report of Proceedings of Sixty-Second Tax Conference, 2010 Tax Conference, Canadian Tax Foundation, 2011, 36:1-62
  • Co-author, “Partnership Freezes – Feasible or Not? Krauss v. The Queen 2009 DTC 2155,” Estates, Trusts and Pensions ‎Journal, December 2010.
  • Co-author, “Convertible Debt Obligations – the Canada Revenue Agency Provides Some Comfort on ‘Traditional’ Convertible ‎Debentures,” Corporate Finance, 2009 Vol. XVI, No. 1‎
  • Author, “Loans Made in the Ordinary Course of a Money Lending Business – Heron Bay Investments Ltd. v. The Queen,” ‎Corporate Finance, 2009 Vol. XVI No. 2.
  • Co-author, “The Taxation of Partnerships in Canada,” Bulletin for International Taxation, 2009, Vol. 63, No. 8/9
  • Co-author, “A Reasoned Response to the CRA’s Views on the Scope and Interpretation of Paragraph 95(6)(b)”, Canadian Tax ‎Journal, (2006), Vol. 54, No. 3, pp. 571 – 632 (Awarded the 2007 Douglas J. ‎Sherbaniuk Distinguished Writing Award by the Canadian Tax Foundation)
  • Co-author, “Donohue: GAAR Revisited,” Tax Law Update, vol.12 no.1, Ontario Bar Association—Taxation Law Section, ‎August 2001

Seminars

  • Speaker, ‎“Case Law Update,” What you missed while you were away: Summer 2018 tax ‎developments (Ontario Bar ‎Association/Taxation Law Section), September 20, 2019.‎
  • ‎Speaker, “Taxation of Partnerships”, Tax Law for Lawyers Seminar, (Canadian Bar Association), ‎May 28, 2019‎
  • Speaker, “Case Law Update,” What you missed while you were away: Summer 2018 tax ‎developments (Ontario Bar ‎Association/Taxation Law Section), September 12, 2018 ‎
  • Speaker, “Taxation of Partnership Reorganizations,” Seminar : Tax Considerations of Corporate ‎Reorganization ‎‎(Wolters Kluwer), November 30, 2017‎
  • Speaker, “Case Law Update,” What you missed while you were away: Summer 2017 tax ‎developments (Ontario Bar ‎Association/Taxation Law Section), September 28, 2017‎
  • Speaker, "Recent case law, ‎technical ‎interpretations of note and legislative update,” Seminar : ‎Taxation of Partnerships, 3rd edition (Wolters Kluwer), July 3, 2017‎
  • Co-presenter, “Preparing a Persuasive Notice of Objection: Maximize the Chances of Winning Your ‎Assessment Challenge,” ‎‎2016 Commodity Tax Symposium, (Chartered Professional Accountants), ‎October 26, 2016 (Toronto)‎
  • Speaker, "Principles governing the ‎computation of income earned ‎through a partnership and determination of a partnership interest’s ‎ACB,” Taxation of Partnerships Seminar, (CCH, ‎‎2015) June 8, 2015 and June 9, 2015‎
  • Co-presenter, “A Primer on Partnerships,” Extracurricular Workshop, 65th Annual Tax Conference, ‎‎(Toronto: Canadian ‎Tax Foundation, 2013) November 24, 2013‎
  • Speaker, “Loss Utilization”, Seminar on Financial Creativity for Quebec Enterprises, APFF, June 17 ‎and 18, 2003‎
  • Co-presenter, “Paid-up Capital and Contributed Surplus”, Seminar on American Financing in Difficult Times, APFF, December 5-6, 2001 and ‎February 6-7‎
  • Co-presenter, “Estate Freezes – Traps and Pitfalls,” ‎Colloquium— Estate Planning, 95, Montreal, APFF, 200, pp. 2:1–57‎

Other

  • Adjunct Professor, Tax LLM Program (Taxation of ‎Partnerships and Tax Shelters)‎, York University, ‎Osgoode Hall Law School
  • Instructor, Tax Law for Lawyers program (Partnership Taxation) Canadian Bar Association

Memberships And Affiliations

  • Canadian Tax Foundation
  • International Fiscal Association
  • Canadian Bar Association (Ontario Section)‎

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Phone

+1 416 862 3397
(Work, Toronto)
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