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  • Free Consultation
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Recognized as one of Canada's Top Tax Law Boutiques.

         
  • Free Consultation
  • Tax Services
    • Voluntary Disclosure
    • Audit
    • Objection
    • Tax Court of Canada
    • Cryptocurrency
    • Unfiled Returns
    • Tax Debt
    • Taxpayer Relief
    • Residency
    • More Services
      • Disability Tax Credit
      • Avoiding Bankruptcy
      • Criminal Defence
      • Judicial Review
      • Rectification
      • Remission Orders
      • Tax Planning
      • Business Advisory
  • Corporate Services
    • Acquisitions
    • Business Formation
    • Commercial and Residential Leasing
    • Commercial Contract Drafting and Review
    • Commercial Financing
    • Corporate Law and Record Maintenance
    • Corporate Reorganizations
    • Mergers
  • Our Firm
    • Our Team
    • About Us
    • Results
    • Decisions
    • Testimonials
    • Careers
      • Student Committee
  • Tax Law Blog
  • Contact Us
logologo
  • Free Consultation
  • Tax Services
    • Voluntary Disclosure
    • Audit
    • Objection
    • Tax Court of Canada
    • Cryptocurrency
    • Unfiled Returns
    • Tax Debt
    • Taxpayer Relief
    • Residency
    • More Services
      • Disability Tax Credit
      • Avoiding Bankruptcy
      • Criminal Defence
      • Judicial Review
      • Rectification
      • Remission Orders
      • Tax Planning
      • Business Advisory
  • Corporate Services
    • Acquisitions
    • Business Formation
    • Commercial and Residential Leasing
    • Commercial Contract Drafting and Review
    • Commercial Financing
    • Corporate Law and Record Maintenance
    • Corporate Reorganizations
    • Mergers
  • Our Firm
    • Our Team
    • About Us
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    • Decisions
    • Testimonials
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      • Student Committee
  • Tax Law Blog
  • Contact Us
  • Free Consultation
  • Tax Services
    • Voluntary Disclosure
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    • Objection
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    • Residency
    • More Services
      • Disability Tax Credit
      • Avoiding Bankruptcy
      • Criminal Defence
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      • Rectification
      • Remission Orders
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  • Corporate Services
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    • Commercial and Residential Leasing
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  • Contact Us

Leading Canadian Tax Lawyers

Legal Team

James Pendergast VCARD

James Pendergast

Position:
Senior Managing Associate
Email:
james@rosentaxlaw.com
Phone:
(416) 593-4357

Personal Experience

James Pendergast is a Senior Managing Associate Lawyer at Rosen and Associates Tax Law.

At R&A Tax Law, James assists clients with the Canada Revenue Agency’s administrative appeals process and through litigation before the Tax Court of Canada and Federal Court. He has worked on matters including complex audits, appeals, real estate dispositions, cryptocurrency, small business tax issues, tax shelter structures, and indigenous taxation issues amongst various others.

James is our trusted Senior Managing Associate and commenced his legal career with R & A Tax Law as a Summer Student (19), returned as an Articling Student (20), and following his callto the Bar in Ontario (21) as an Associate.

James has been the Director of Student Development at R & A Tax Law since 2023 and has been the inaugural Director of the firm’s Health and Wellness Committee since January of 2025. His passions for fitness, mental health and wellness and employee wellbeing have underscored his coordination of firm yoga classes and fitness-oriented team events such as firm rock climbing and spin classes.

James was conferred his Juris Doctor degree University of Toronto Faculty of Law in June of 2020. During his legal education, James was a chair of the Faculty of Law’s Health and Wellness Committee, volunteered with the Law in Action Within Schools (LAWS) program and was an Associate Editor with the University of Toronto Law Review. In 2019, James competed for the University of Toronto at the 2019 Donald G. H. Bowman National Tax Moot and helped the 2020 team. James attended the School of Law at Trinity College Dublin in Dublin, Ireland for the fall semester of his final year of law school.

Prior to attending University of Toronto, James majored in Spanish at Dalhousie University and studied on exchange at Universidad Autónoma de Campeche in Campeche, Mexico. At Dalhousie, James was awarded the President’s Scholarship for outstanding academic achievement and graduated with Distinction.

James was raised on Prince Edward Island before moving to Nova Scotia for university. He grew up playing basketball, volleyball, tennis and running track and field. When not at work, he enjoys anything active, cooking and travelling.

Media

US Tax Rule Offers Template for Canadian Conservatives’ Investment Pitch (Bloomberg)

US Tax Rule Offers Template for Canadian Conservatives’ Investment Pitch (Financial Post)

Recent Decisions

Xu v. HMK, 2021-1015(GST)APP – Tax Court of Canada (incorrect decision regarding GST/HST)

Bukhari v HMK, 2021-1705(IT)I

Bukhari v HMK, 2021-1706(IT)I

Kilpatrick v HMK, 2021-2502(IT)I

Knaff v HMK, 2020-1016(IT)I

Behnke v HMK 2021-1061(IT)G

Broderick v HMK 2021-860(IT)G

Coward v HMK 2021-871(IT)G

Velasquez v HMK 2020-1000(IT)G

Ord v HMK 2020-1604(IT)G

Greenham v HMK 2020-2066(IT)G

Kares v HMK 2020-453(IT)G

O’Hara v HMK 2020-481(IT)G

The Estate of the Late Wilfredo Farias v HMK 2020-540(IT)G

Roth v HMK 2020-963(IT)G

Bradley v HMK 2020-978(IT)G

Rajendram v. HMQ, 2020-267(GST)I – Tax Court of Canada (Settlement completed, Taxpayer entitled to New Home Housing Rebate)

McLean v. HMQ, 2020-630(IT)I – Tax Court of Canada (Settlement to allow all foreign tax credits claimed)

6478620 Canada Inc. v. HMK, 2020-409(IT)G

ASIF v. HMK, 2020-538(IT)G

Verrelli v. HMK, 2019-594(IT)G

Ghosh v HMK, 2019-3260(IT)G

Hsu v HMQ, 2019-1334(IT)G

Don’t Forget Me Doggies Inc. v HMK, 2019-3261(IT)G

Rutledge v. HMQ, 2018-3388(IT)G – Tax Court of Canada (Section 160 assessment vacated following settlement with the Department of Justice)

Mong, Tung Le v HMK, 2017-5072(IT)G

Dhingra v. HMK, 2017-3794(IT)I – Tax Court of Canada (Reducing taxpayer income)

Idone v HMK, 2015-2699(IT)G

Maconachie v A.G.C., T-1430-21 – Federal Court (Through settlement with the Department of Justice, the Applicant’s judicial review request was sent back to the CRA for a fresh review)

Wilfredo v MNR., T-113-21 – Federal Court (RRSP over-contribution penalty removed through a settlement with the Department of Justice)

Blog Posts

Corporate Tax Audit Documentation

Corporate Tax Audit Documentation

When the Canada Revenue Agency (the “CRA”) selects a corporation for an audit, one of the first steps is requesting supporting records. The quality,...

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Land Transfer Tax in Canada: What Buyers Need to Know

Land Transfer Tax in Canada: What Buyers Need to Know

When purchasing real estate in Canada, many buyers focus on the price of the home but forget about a major additional cost: land transfer tax. This one-time...

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Corporate Tax Audit Red Flags

Corporate Tax Audit Red Flags

The Canada Revenue Agency (the “CRA”) uses advanced data analysis and risk assessment to decide which corporations to audit. While not every irregularity...

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Car Allowance CRA: For Employers and Employees

Car Allowance CRA: For Employers and Employees

Whether you are an employer providing vehicle-related compensation or an employee receiving it, understanding how the Canada Revenue Agency (the “CRA”)...

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Small Business Corporate Tax Audit

Small Business Corporate Tax Audit

Small businesses form the backbone of the Canadian economy, but they are not exempt from scrutiny by the Canada Revenue Agency (the “CRA”). A small business...

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Tax Implications of Selling Your Principal Residence in Ontario

Tax Implications of Selling Your Principal Residence in Ontario

Under section 54 of the Income Tax Act (the “Act”), a principal residence is generally defined as a housing unit (including leasehold interest or shares in...

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Navigating the CRA Objection Process: What Every Taxpayer Should Know

Navigating the CRA Objection Process: What Every Taxpayer Should Know

If you have received a decision, Notice of Assessment, Reassessment, or Determination from the Canada Revenue Agency (“CRA”), filing a Notice of Objection...

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How to Report Cryptocurrency Gains or Losses to the CRA

How to Report Cryptocurrency Gains or Losses to the CRA

As cryptocurrency has become more mainstream, the Canada Revenue Agency (CRA) has tightened its expectations around reporting crypto transactions. If you’re...

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Owning Rental Property Through a Corporation

Owning Rental Property Through a Corporation

Owning rental property has become an increasingly popular and effective strategy for long-term wealth accumulation. In response, individuals are becoming...

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Understanding the Tax Implications of House Flipping in Canada

Understanding the Tax Implications of House Flipping in Canada

House flipping has become a popular way for many Canadians to invest in real estate. The concept is simple: buy a residential property, renovate it, and...

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