Jennifer Flood represents clients in the most high-stakes tax disputes
Jennifer is a partner practicing in the firm’s Vancouver office. She represents companies and individuals in complex tax litigation, in both the civil and criminal contexts. She guides her clients through all stages of interaction with the tax authorities including tax audits, administrative appeals, trials in the Tax Court of Canada, judicial review applications, and appeal proceedings.
She also represents clients who are the targets of criminal investigations and prosecutions for tax evasion and related offences such as Criminal Code fraud and forgery. Trained as both a tax lawyer and as criminal defence counsel, she brings a unique combination of skills to criminal tax cases. She has appeared before all levels of court in British Columbia, the Federal Court and Federal Court of Appeal.
- successfully appealed reassessments issued to mining companies under B.C.’s Mineral Tax Act in the BC Supreme Court and defended against applications by the Ministry of Finance for leave to appeal these judgments to the B.C. Court of Appeal;
- represented clients in disputes over tax reassessments under the General Anti-Avoidance Rule (GAAR);
- acted for clients in high-profile tax evasion and fraud prosecutions in the B.C. Provincial Court and the B.C. Supreme Court;
- assisted clients in making applications to the CRA’s voluntary disclosures program (VDP);
- acted for clients subject to search and seizure of documentation and electronic devices by the Canada Revenue Agency, including litigation related to the protection of solicitor client privilege;
- assisted clients in navigating concurrent investigation and enforcement actions by Canadian tax authorities and other agencies such as police, the B.C. Securities Commission, the B.C. Director of Civil Forfeiture, and the IRS; and
- acted for clients in Charter challenges against actions by tax authorities and challenges to the constitutional validity of legislation.
In her active pro bono practice, Jennifer assists low income clients with various issues affecting them such as disputes regarding their benefit entitlements and applications for relief from interest and penalties on overdue taxes. She also represents individuals and community organizations in public interest litigation, including constitutional cases.
Jennifer writes on a variety of tax issues and her work has been published in Thomson Reuters’ Tax Times and the Canadian Tax Foundation’s Canadian Tax Highlights. She is a frequent speaker on tax issues, including for CLEBC and the Pacific Business & Law Institute.
Jennifer received her B.Sc. (Honours, Physics) from Queen’s University and her J.D. from the University of British Columbia. Prior to joining the firm, she clerked at the British Columbia Court of Appeal.