Osnat Nemetz
Biography
Osnat Nemetz is a senior associate in Baker McKenzie's Tax Practice Group in Toronto. Osnat focuses on tax litigation and dispute resolution, in which she acts as counsel on behalf of clients for a variety of federal and provincial income tax matters.
Osnat guides clients through all levels of tax disputes, including complex Canada Revenue Agency audits, administrative objections and each stage of litigation. Osnat has appeared before the Tax Court of Canada, the Federal Court, the Ontario Superior Court of Justice, the Federal Court of Appeal and the Supreme Court of Canada.
Prior to joining the firm, Osnat was an associate at a law firm affiliated with an international accounting firm. She started her career at a boutique tax law firm in Toronto.
Practice Focus
Osnat's practice focuses on assisting taxpayers in complex tax disputes, either at audit, trial or appellate courts, on matters such as the application of the general anti-avoidance rule, transfer pricing, characterization of income, Ministerial discretionary decisions, employer payroll taxes and the imposition of penalties. In each matter, Osnat takes a practical, yet detailed, approach in providing thorough solutions for her clients.
Representative Legal Matters
Osnat has litigated cases involving:
- The Minister of National Revenue's decision to deny a downward transfer pricing adjustment.
- The CRA's misallocation of income in respect of a life insurance provider.
- The CRA’s decision to reject an amended election in respect of the transfer of property to a corporation.
- The CRA’s attempt to apply filing and gross negligence penalties.
- The CRA's attempt to apply the offshore investment fund property rules.
Professional Associations and Memberships
- Canadian Tax Foundation
- Ontario Bar Association
- Canadian Bar Association
- The Advocates' Society
Admissions
- Ontario~Canada (2017)
Education
- Osgoode Hall Law School (J.D.)
- Yeshiva University (B.A. (Hons), Economics & English Literature)
Languages
- English
- Hebrew