Robert Carvalho focuses on representing taxpayers involved in complex audits involving the anti-avoidance provisions of the Income Tax Act, including the general anti-avoidance rule and transfer pricing provisions. Having worked for the Department of Justice Canada for over 25 years, he has gathered unparalleled experience at all court levels on such files. He has been involved in numerous files at the Tax Court of Canada and Federal Court of Appeal involving the general anti-avoidance rule, including the first such appeal to go to the Federal Court of Appeal. In addition, his experience has given him insight into the Canada Revenue Agency audit process and has resulted in him being involved in many of the precedential cases involving the use of the CRA’s audit powers.
