- Planning and executing tax-efficient strategies for the selling shareholders of a national retail chain
- Planning and executing tax-efficient structures for Canadian companies expanding abroad, as well as for multinationals inbound to Canada
- Advising public and private companies on establishing formal policies governing the use of corporate aircraft
- Tax planning for acquisitions and divestitures, including structuring earn-out transactions and other tax-efficient strategies for vendors
- Tax planning for individuals immigrating to or departing Canada
- Extensive experience in representing clients with regard to the voluntary disclosure programs of both the Canada Revenue Agency and Revenue Québec, especially as pertains to offshore bank accounts
Steven Sitcoff is a highly experienced lawyer with a practice primarily focused on providing domestic and international corporations with proactive and practical tax planning solutions to assist them to further their business objectives. He has significant experience working with private and public companies from various sectors including consumer products, retail, real estate, financial services, and entertainment.
Steven provides comprehensive legal and tax advice to Canadian companies with national and cross-border activities as well as to companies from abroad expanding into Canada.
Steven is repeatedly called upon for his unique combined expertise in taxation and private aviation matters. In this capacity he is frequently consulted by clients and aviation services firms across Canada to advise on tax-efficient acquisition and ownership structures for aircraft, to review aircraft ownership structures and usage policies for tax risk, and for representation in aircraft-related audits and tax disputes. Steven also has extensive experience in advising vendors, purchasers, and financiers of aircraft as regards the Select Luxury Items Tax Act (i.e., the Canadian luxury tax).
Steven regularly represents both corporate and individual clients in tax disputes with the federal and provincial tax authorities. A member of both the Québec and Ontario bars, Steven fulfilled his articling requirements as a law clerk to the judges of the Tax Court of Canada.
Tax and Legal Considerations for Aircraft Owners, at the 2022 National Convention of the Canadian Business Aviation AssociationJune 15, 2022
Tax and financial planning for business aircraft owners, Co-presenter at 2019 National Convention of the Canadian Business Aviation AssociationJuly 10, 2019
How to manage the impact of CRA’s new tax policy, Co-presenter at 2018 National Convention of the Canadian Business Aviation AssociationJune 14, 2018
Tax Planning for Your Business Aircraft, Co-presenter at 2017 National Convention of the Canadian Business Aviation AssociationAugust 11, 2017
Taxation of personal use of business aircraft, Co-presenter of Webinar to the Canadian Business Aviation AssociationJuly 15, 2017
Taxation of personal use of business aircraft, Co-presenter of Webinar to the Canadian Business Aviation AssociationApril 28, 2016
- “CBAA makes headway on taxation issue,” Skies Magazine (June 28, 2018)
- “CBAA musters the troops in response to taxable benefits proposal,” Skies Magazine (August 15, 2017)
Rankings & Recognitions
- Recognized in the 2023 Canadian Legal Lexpert Directory as a Repeatedly Recommended Lawyer in the area of Aviation
- Chair of the Innovations Committee of the Jewish Community Foundation of Montréal: 2013 to present
- 2019 West Island Campaign Chair, Federation-CJA (Montréal)
- Member of the Board of Directors and Secretary to the Board of West Island College: 2015 to 2022
- Board Member, Jewish Community Foundation of Montréal: 2008-2013
Directorships & Affiliations
- Le Barreau du Québec
- Law Society of Ontario
- Canadian Tax Foundation (CTF)
- International Fiscal Association
- Canadian Business Aviation Association
Education & Admissions
- “Facing the Aircraft Luxury Tax,” Wings Magazine (March/April 2023)
- “Not yet cleared for takeoff,” Wings Magazine (May/June 2022)
- “Inside Canada’s proposed luxury tax,” Wings Magazine, p. 24-26 (September/October 2021)
- “So, you want to buy an aircraft? Tips from a lawyer,” Skies Magazine (February 5, 2021)
- “CRA’s New Tax Policy on Business Aviation: One Year Later ,” Wings Magazine (May/June 2019)
- “CRA’s new policy on personal use of bizjets – What you need to know about the personal use of corporate aircraft,” Wings Magazine (May 2018)
- “Sorting out the details,” Wings Magazine (October 26, 2017)
- “Voluntary Tax Disclosures: Dispelling the Myths,” The Gazette (October 27, 2011)
- “TESCM Planning,” Canadian Tax Highlights, vol. 19, No. 2 (February 2011)
- “Transaction Costs Revisited,” Canadian Tax Highlights, vol. 11, No. 5 (May, 2003)
- “Stock Option Terminated,” Canadian Tax Highlights, vol. 9, No. 1 (January 23, 2001)
Insights (5 Posts)
Budget 2023: Alternative Minimum Tax
Budget 2023 proposes the first major changes to the Alternative Minimum Tax (the “AMT”) since its introduction in 1986
Canada’s Luxury Tax: Practical challenges for the aviation industry
To date, the Canada's Luxury Tax remains poorly understood notwithstanding that it is expected to have a broad impact on key industries.
Not Yet Cleared for Takeoff: Draft Canadian Luxury Tax Legislation Raises Concerns for the Aviation Industry
On March 11, 2022, the federal Department of Finance released draft legislative proposals to implement the proposed Luxury Tax.
Remote Working Arrangements: Tax Planning & Pitfalls
Discussion of tax considerations related to remote working arrangements such as appropriate payroll withholding rates and permanent establishment issues.
Clipping Wings and Stalling Engines: The proposed Canadian federal luxury tax raises issues for vendors, manufacturers, service providers and consumers
Proposed Canadian federal luxury tax raises issues for the aviation, automotive and boat industries
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