Verified profile

Bryan Horrigan

Partner, Indirect Tax at Baker McKenzie LLP

Bryan Horrigan's profile photo
LocationTorontoOntario, Canada
Current rolePartner, Indirect TaxBaker McKenzie LLP · since Jan 2022
Government service9yrsDepartment of Finance Canada · Canadian Forces

About

Bryan Horrigan is a partner in Baker McKenzie's Tax Practice Group in Toronto. Prior to joining the Firm in 2018, Bryan was a lawyer with a boutique tax law firm in Toronto, providing advice on indirect tax and trade matters in both planning and dispute resolution contexts.

Roles

Jan 2022–Present
Current role

Partner, Indirect Tax

Baker McKenzie LLP

Toronto, Canada

Attorney AdvisorTax ExaminingTax AttorneyTax Law

Bryan's practice is focused on Canadian Goods and Services Tax (GST)/Harmonized Sales Tax (HST), provincial sales tax (PST) and other Canadian indirect taxes, as well as Digital Services Tax (DST). This involves tax advice in the context of general planning/compliance, controversy/dispute resolution, mergers and acquisitions, and policy advocacy. Bryan provides advice to businesses in all industry sectors, with primary focus on high-tech and e-commerce businesses. He has appeared as counsel at the Tax Court of Canada, Federal Court of Canada and the Federal Court of Appeal on significant GST/HST disputes.

Mar 2018–Present
Current role

Indirect Tax Lawyer

Baker McKenzie LLP

Toronto, Canada

Attorney AdvisorTax AttorneyTax Law

Maintains a practice focused on Canadian Goods and Services Tax (GST)/Harmonized Sales Tax (HST), provincial sales tax (PST) and other Canadian indirect/commodity taxes. This includes both advisory work and dispute resolution in all industry sectors.

Sep 2014–Mar 2018
Former role

Indirect Tax Lawyer

Millar Kreklewetz LLP

Toronto, Canada

International Trade LawTax AttorneyTax Law

Assisted clients with customs, international trade, GST/HST, PST, and other sales, use and indirect tax issues. This includes assistance with both planning matters and resolving tax and customs disputes with the Canada Revenue Agency and Canada Border Services Agency.

Notable cases:
Canada v. 407 ETR Concession Company Limited, 2017 FCA 220
Stewardship Ontario v. The Queen, 2018 TCC 59

Aug 2011–Sep 2014
Former role

Lawyer

Miller Thomson LLP

AttorneyLegal

Lawyer (Jul 2012 - Sep 2014)

Articling Student (Aug 2012 - Jun 2012)

Jan 2009–Dec 2009
Former role

Intern/Summer Student

Department of Finance Canada, Financial Institutions Division

(appointed)Ottawa, Canada

EducationGovernmentFinance
Jun 2003–Jun 2012
Former role

Signal Operator

Canadian Forces, Reserves

Toronto, Canada

Military and Protective ServicesMilitary / DefenseMachine Operator

Publications & speeches

New Sales Tax Collection Obligations Coming in Québec for Non-Resident E-Commerce Suppliers

Lexology

June 2018

The province of Québec has released proposed legislation to implement measures originally announced in the March 27, 2018 Québec budget (“Budget”) with respect to Québec Sales Tax (“QST”) and e-commerce in Québec, notably registration and collection requirements for non-resident suppliers of “incorporeal movable property” (i.e., intangible property) and services (“E-Commerce Supplies”). The legislation has been introduced as an amendment to an omnibus budget bill (Bill 150).

Link

Credit Notes from Impecunious Suppliers

Canadian Tax Highlights, Volume 25, Number 6

June 2017

Case Comment re: North Shore Power Group Inc. v. The Queen (2017 TCC 1)

Supreme Court Shuts Out Importer in its First Customs Tariff Decision

CBA Commodity Tax, Customs and Trade Section Newsletter

March 2017

Case comment re: Canada (Attorney General) v. Igloo Vikski Inc., 2016 SCC 38.

Link

Expanding the Place of Supply Rules?

Canadian Tax Highlights, Volume 24, Number 9

September 2016

Case comment re: Club Intrawest v. The Queen (2016 TCC 149)

Link

Admissibility of Accountant’s Statements in Court

Tax for the Owner-Manager, Volume 16, Number 3

July 2016

Case comment re: R. v. Spears (2016 NSPC 20)

Link