Jas Gill
Tax Lawyer
Jas Gill (he/him) is a tax lawyer at Taxpayer Law. He was called to the Ontario Bar in 2024 and previously served as an associate at a prominent Bay Street law firm.
Jas focuses his practice on advising clients on, and litigating, income tax and GST/HST disputes with the CRA. He is known for his meticulous attention to detail, clear communication, and ability to navigate nuanced tax laws with confidence. Whether challenging reassessments, negotiating with the CRA, or advocating in the Tax Court of Canada, he is committed to achieving practical and favourable outcomes for his clients. Jas earned his Juris Doctor from the University of Toronto, where he served as Co-Editor-in-Chief of the Indigenous Law Journal for two years. He holds a Bachelor of Commerce (Honours) from McMaster University, where he was awarded the Burton R. James Memorial Prize for graduating at the top of his class.
Education
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University of Toronto Faculty of Law, JD
2023
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McMaster University, Bachelor of Commerce (Honours)2020
Areas of Focus:
- Builder assessments and self-supply issues. Jas handles GST/HST disputes about whether a person is a “builder” and whether a deemed self-supply has arisen on newly constructed or substantially renovated residential property. The key statutory anchors are the builder definition in ETA subsection 123(1) and the self-supply rules in section 191, with common client scenarios involving owner-builders, one-off developers, renovators, and residential real-estate ventures that did not initially understand the GST/HST consequences of first occupancy or first lease.
- Income versus capital gain recharacterization. Jas handles income tax disputes about whether a gain, loss, or receipt should be treated on income account or capital account. The key statutory anchors often include the income inclusion rules in ITA section 9, the capital gains rules in subdivision C, and the “adventure or concern in the nature of trade” concept in subsection 248(1). Common client scenarios involve taxpayers who sold real estate, securities, business assets, or other property and later face reassessments because the CRA questions their intention, holding period, pattern of activity, financing, marketing efforts, business context, or the commercial circumstances surrounding the purchase and sale.
- Carousel scheme assessments and ITC denial issues. Jas handles GST/HST disputes where the CRA alleges that a taxpayer was involved in a carousel scheme, circular trading arrangement, or other transaction chain used to claim improper input tax credits, rebates, or refunds. The key statutory anchors often include the ITC rules in ETA section 169, the documentary requirements in subsection 169(4) and the Input Tax Credit Information Regulations, and penalty provisions where the CRA alleges the taxpayer knew or should have known that the transactions were improper. Common client scenarios involve businesses that purchased and resold goods or services through supplier and customer chains, later facing reassessments because the CRA questions whether the transactions were commercially real, whether the suppliers were legitimate, whether GST/HST was properly charged and remitted, or whether the taxpayer took reasonable steps to verify the transactions.
- CRA Collections and Enforcement. Jas assists taxpayers facing collections letters, requirements to pay, garnishments, certificates, liens, and other time-sensitive enforcement under sections 223, 224 and 225.1 of the Income Tax Act (Canada) and sections 316 and 317 of the Excise Tax Act. These matters often involve organizing financial records, tracking deadlines, assessing collection restrictions, protecting cash flow, and positioning the file for payment-arrangement discussions or other practical resolutions.
Publications / Events / Media
- Author, “Case Summary: His Majesty the King v. Vefghi Holding Corporation and S.O.N.S. Environmental Ltd.”, November 2025.
- Author, “GST/HST Obligations and Rebates for Canadian Builders”, June 2025.
- Speaker, The Association of Professional Accounting and Tax Consultants, When CRA Disputes Escalate
