Jason Rosen
Personal Experience
Jason Rosen is a founding Partner at Rosen & Associates.
Jason provides effective and aggressive representation by taking a proactive, client centered approach for his domestic and international clients alike. Throughout his time in the field, Jason has gained a comprehensive understanding of tax procedures and the dispute resolution process. Jason advises a variety of clients involved in a broad range of disputes with provincial and federal tax authorities. Jason successfully represents a large range of clientele, from individual taxpayers to small and medium size corporations. Jason has been counsel of record on matters at the Tax Court of Canada, Ontario Superior Court of Justice and the Federal Court of Appeal.
Not only is Jason a litigator, he also assists clients throughout the audit and objection processes. Furthermore, Jason delivers effective negotiations with respect to collections arrangements, drafts applications for taxpayer relief to eliminate interest and penalties as well as manages all aspects of the Voluntary Disclosures Program.
Jason holds a Bachelor of Commerce in Accounting from Ryerson University. He began his law career studying abroad at Bond University in Gold Coast, Australia, and completed his JD at the University of Windsor Ontario.
Jason’s experience has equipped him with the ability and capacity to provide tax related advice of the highest quality. During Jason’s spare time, he enjoys travelling, playing hockey and golf, and keeping up with technological trends.
Recent Decisions
Goldhar v HMK, 2023 TCC 30
The Estate of the Late Cazmer Wisniewski v Attorney General of Canada, T-307-22
Xu v. HMK, 2021-1015(GST)APP – Tax Court of Canada (incorrect decision regarding GST/HST)
Torabi v. HMQ, 2021-512(IT)G – Tax Court of Canada (Business income was re-characterized as a capital gain, and gross negligence penalties were removed)
Behnke v HMK 2021-1061(IT)G
Broderick v HMK 2021-860(IT)G
Coward v HMK 2021-871(IT)G
Bukhari v HMK, 2021-1705(IT)I
Bukhari v HMK, 2021-1706(IT)I
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
6478620 Canada Inc. v. HMK, 2020-409(IT)G
ASIF v. HMK, 2020-538(IT)G
McLean v. HMQ, 2020-630(IT)I – Tax Court of Canada (Settlement to allow all foreign tax credits claimed)
Verrelli v. HMK, 2019-594(IT)G – Tax Court of Canada (Taxable gains associated with home purchase)
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
Wong v. HMQ, 2019-2427(GST)I – Tax Court of Canada (Appellant allowed New Home House Rebate. Minister did not even issue a Reply)
Rutledge v. HMQ, 2018-3388(IT)G – Tax Court of Canada (Section 160 assessment vacated following settlement with the Department of Justice)
Isbister v. HMQ, 2018-3922(IT)I & Spafford v. HMQ, 2018-3928(IT)I – Tax Court of Canada (Appellant allowed all interest expenses)
Proulx v. HMQ, 2018-3780(IT)G – Tax Court of Canada (Business expenses were allowed through settlement)
Smith v. HMQ, 2018-2275(IT)I & 2018-2276(IT)I – Tax Court of Canada (Donations allowed, and gross negligence penalties removed following hearing at the Tax Court)
Melen v. HMQ, 2018-3107(IT)G – Tax Court of Canada (Appellant allowed his employment expenses through a settlement with the Department of Justice)
Smith v HMQ, 2018-3782(IT)G
Juriansz v. HMQ, 2017-3563(IT)G & 2018-705(GST)G – Tax Court of Canada (Appellant allowed principal residence exemption, removal of GST/HST and penalties)
Prasher v. HMQ, 2017-3097(IT)G -Tax Court of Canada (Principal residence exemption originally denied, but settlement successfully allowed the claim)
Beaudrow v. HMQ, 2017-1896(IT)G – Tax Court of Canada (Appellant’s shareholder benefit reduced by hundreds of thousands of dollars)
1501954 Ontario Inc v. HMQ, 2017-1897(GST)G & 2017-1894(IT)G – Tax Court of Canada (Appellant allowed additional expenses, and taxable income lowered by over a hundred thousand dollars)
Dhingra v. HMK, 2017-3794(IT)I – Tax Court of Canada (Reducing taxpayer income)
Mong, Tung Le v HMK, 2017-5072(IT)G
Timberview Developments Ltd v HMQ, 2017-5004(IT)G
Ebiye v HMQ, 2017-3229(IT)G
Morgan v HMQ, 2017-5005(IT)G
Acosta v. HMQ, 2016-3936(IT)I – Tax Court of Canada (Travel expenses were allowed through settlement)
Wood v HMK, 2016-1919(IT)G
Chan v. HMQ, 2016-5049(IT)G – Tax Court of Canada (Appellant entitled to principal residence exemption on the sale of a home owned for a few short months)
Kasik v. HMQ, 2016-3166(IT)I – Tax Court of Canada (Appellant allowed to deduct 70% of claimed expenses)
Lu v. HMQ, 2016-2414(IT)I – Tax Court of Canada (Appellant allowed $48,652.33 of expenses and gross negligence penalties deleted)
Sakaria v. HMQ, 2016-237IT(G) – Tax Court of Canada (Loan forgiveness considered valid consideration in lowering a Section 160 Assessment issued against the taxpayer)
Robertson Amusements Ltd, 2015-1261(GST)G – Tax Court of Canada (Appellant’s taxable income reduced by $2,575,000, and Appellant’s GST/HST reduced by $325,000)
Idone v HMK, 2015-2699(IT)G
Stubbs, Christina v HMQ – 2015-2206(IT)G
Stubbs, Colin v HMQ – 2015-2208(IT)G
Stubbs, Colin v HMQ – 2015-3301 (GST)I
Eghbalkhah v HMQ, 2015-4704(IT)I
Juriansz v. HMQ, 2015-3945(IT)G – Tax Court of Canada (Appellant allowed principal residence exemption, removal of GST/HST and penalties)
2189788 Ontario Inc. v. HMQ, 2015-5012(IT)G – Tax Court of Canada (Appellant income reduced by $4.53 million dollars which was 85% of what CRA assessed as unreported income)
Wilfredo v MNR., T-113-21 – Federal Court (RRSP over-contribution penalty removed through a settlement with the Department of Justice)
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)
Lee v. MNR, T-1884-17 – Federal Court (Judicial Review of decision not to allow taxpayer relief, settlement allowing relief)
Northcut v. Ontario (Minister of Finance), 184-17 – Ontario Superior Court of Justice (Minister vacated Director’s Liability Assessment)
Gingell v. MNR, T-1283-16 – Federal Court (Taxpayer entitled to taxpayer relief and awarded full costs)
Boroumand v. Canada, 2016 FCA 313 – Federal Court of Appeal
Mendes, Godfrey v HMQ
HSU, Vicky v HMQ
Media
Cyrptocurrency, Coinbase and Tax Evasion