David D Robertson


David is one of Canada’s leading tax litigators. David is also one of Canada’s leading sales & indirect tax specialists. He is a member of the Canadian Institute of Chartered Accountants’ 25-member GST/HST Leaders’ forum, and is a co-instructor of the Institute’s Annual National GST/HST Tax Course.

David has been selected by his peers to appear in The Canadian Legal Expert Directory, validation that he is a leading lawyer in his practice area, according to the Lexpert's annual peer survey.

EY - Lexpert Ranked Lawyer


Formerly counsel with the Canadian Department of Justice Tax Law Services, David’s experience includes resolving all forms of tax disputes – through rulings, objections, appeals, or settlement – including international transfer pricing, general anti-avoidance rule (GAAR) assessments (federal & provincial), residency & permanent establishment issues, partnership deferral arrangements, valuation, thin-capitalization, treaty & statutory interpretation, complex corporate reorganizations, directors’ liability, debt forgiveness, employee & shareholder benefits, GST/HST, PST, international transportation, native tax exemptions, insurance premium taxes, as well as tax collection, taxpayer relief, and third-party liability assessments.


  • Member, Canadian Bar Association
  • Barrister & Solicitor (Alberta 2011, Ontario 1999, British Columbia 1995)
  • Bachelor of Laws (University of British Columbia 1994)
  • Bachelor of Journalism & Economics (Carleton University 1990)

Professional Accomplishments

  • He is a member of the Canadian Bar Association’s/Tax Court of Canada’s Bench & Bar Committee, and was a contributing editor to GAAR Interpreted: The General Anti-Avoidance Rule.
  • Canadian tax counsel and advisor to a number of Fortune 500 companies, including oil and gas, energy producers, international & national retailers (traditional and internet), telecom service providers, leading technology manufacturers, programmers, & service providers, financial and insurance service providers (including Lloyds’), real property & construction enterprises.

Cases & Publications

Reported Cases

  • Maritime-Ontario Freight Lines Ltd. v. The Queen, [2009] G.S.T.C. 130 (TCC)
  • Y.S.I.’s Yacht Sales International Ltd. v. The Queen, 2007 TCC 306
  • H & R Block Canada Inc. v. The Queen, 2006 TCC 102
  • Spie Construction Inv. v. Minister of Finance (Ontario), 2055 G.T.C. 1460 (Ont. CA)
  • Specialty Manufacturing v. The Queen, [1999] C.T.C. 82 (FCA)
  • Vanex Truck Service Ltd. v. The Queen, [1999] G.S.T.C. 101
  • Fedderly Transportation Ltd. V. The Queen, [1998] G.S.T.C. 77

Select Publication

  • Implementing a National Value-Added Tax: Lessons Learned from Canada (Tax Executives’ Institutes’ Mid-Year Conference: 2009)
  • Sales Tax Harmonization: The Facts & Nothing But The Facts (Canadian institute of Chartered Accountants’ Canadian Commodity Tax Symposium, 2005)
  • Effective Global Contracting: Canadian Tax Considerations in respect of Cross-border Transactions (Canadian institute of Chartered Accountants’ Canadian Commodity Tax Symposium, 2003)
  • E-Commerce: VAT Issues in Cross-Border Transactions (Tax Executives’ Institute: Doing Business in a Digital Economy, 2001)
  • Provincial Residency & Jurisdictional Matters, 97 BCC 3B 1997


  • Member, The Advocates’ Society