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  • Free Consultation
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  • Free Consultation
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    • Voluntary Disclosure
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    • Unfiled Returns
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    • Taxpayer Relief
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      • Disability Tax Credit
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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
    • Results
    • Decisions
    • Testimonials
    • Careers
      • Student Committee
  • Tax Law Blog
  • Contact Us
  • 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

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

Understanding Canada’s General Anti-Avoidance Rule

Understanding Canada’s General Anti-Avoidance Rule

Effective tax planning is important for both individuals and businesses. Good planning helps you meet your legal obligations while arranging your affairs in...

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Tax Controversy: How Tax Disputes with the CRA Are Resolved

Tax Controversy: How Tax Disputes with the CRA Are Resolved

Tax controversy refers to disputes between taxpayers and the Canada Revenue Agency (“CRA”) over the interpretation or application of the governing tax...

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Ojaide v The King –Tuition Tax Credits Explained

Ojaide v The King –Tuition Tax Credits Explained

Paying for school is stressful enough, but missing out on tuition tax credits or claiming them incorrectly can cost Canadians thousands. As tuition fees...

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New CRA Powers for Notices of Non- Compliance – Proposed in the 2025 Federal Budget

New CRA Powers for Notices of Non- Compliance – Proposed in the 2025 Federal Budget

In the 2025 Federal Budget, the Canadian government proposed plans to introduce a new tool for the Canada Revenue Agency (“CRA”) called a Notice of...

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Foreign Tax Credits: Common Errors and CRA Adjustments

Foreign Tax Credits: Common Errors and CRA Adjustments

When Canadians earn income abroad, through employment, investments, or business activities, that income is typically taxed in the country where it’s earned....

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Understanding the CRA’s Power to Compel Interviews Under Section 231.1

Understanding the CRA’s Power to Compel Interviews Under Section 231.1

The Canada Revenue Agency (CRA) has several key powers regarding the administration and enforcement of Canadian income tax laws. These powers allow the CRA,...

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What to Expect During an Audit — and How to Prepare

What to Expect During an Audit — and How to Prepare

Getting audited by the CRA can be an arduous process, fraught with requests for extensive documentation and information. However, with diligent...

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Salary or Dividends? How Corporation Operators Can Pay Themselves Better

Salary or Dividends? How Corporation Operators Can Pay Themselves Better

If you run an incorporated business, deciding how to pay yourself is a big part of financial planning. The choice usually comes down to salary, dividends,...

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Tax Strategies to Help Your Ontario Small Business Thrive

Tax Strategies to Help Your Ontario Small Business Thrive

Running a successful small business in Ontario comes with its fair share of responsibilities. Having an effective tax plan is a key component to the...

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Taxpayer Relief Applications: How to Request CRA Relief

Taxpayer Relief Applications: How to Request CRA Relief

Most Canadian taxpayers do not enjoy dealing with the Canada Revenue Agency (“CRA”), especially when the penalties and interest start to stack up fast!...

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