Stuart Clark

Stuart's practice is focused on Canadian indirect and commodity taxes, including Canadian Goods and Services Tax (GST), Harmonized Sales Tax (HST), provincial sales taxes (PST), federal excise and provincial taxes on fuel and fuel charges, and employer health tax (EHT). His practice includes both planning and dispute resolution where he advises companies on complex, cross-border and domestic indirect tax matters as well as audit support, objections, voluntary disclosures, and appeals before the Tax Court of Canada. Prior to joining the Firm, he also advised companies on closely related customs matters, including tariff classification, valuation, origin, seizures, transfer pricing, and anti-dumping/subsidy investigations.

Prior to joining the Firm, Stuart assisted with the following matters:

• Advised a global energy trading company on the indirect, carbon, and fuel tax implications of proposed imports/exports of various fuel products into/from Canada.
• Advised and represented a global auto manufacturer on multiple CRA assessments arising out of disallowed input tax credits between closely related business groups, among other issues.
• Advised and represented a global furniture and upholstery company on CBSA anti-dumping and subsidy verifications and successfully secured preferable normal values compared to other exporters.
• Advised a Canadian airline on the indirect tax consequences of importing of leased aircraft into Canada.
• Advised a global manufacturer of construction machinery on structuring its Canadian businesses to minimize indirect tax and customs consequences of new Canadian business lines.
• Advised a major Canadian warehousing and logistics company on the customs regulatory and licensing implications of its acquisition of another warehousing and logistics company.
• Advised and represented a global independent energy trading company on multiple CRA assessments arising out of the proper application of GST to imported, in-bond fuel products.
• Advised and represented several Ontario tobacco wholesalers on Ontario tobacco tax assessments arising from sales to on-reserve, indigenous retailers.
• Advised a Canadian global clothing and apparel label on navigating various customs transfer pricing issues.
• Advised a global dental care product manufacturer on CBSA valuation issues and structuring its Canada-US affairs to mitigate further transfer pricing issues.

• Law Society of Ontario