Angela Salvatore

Angela I. Salvatore BA, JD, LLM (Taxation)
Barrister, Solicitor, and Notary Public

Angela’s practice focuses on all aspects of tax dispute resolution, commencing at the audit stage with the Canada Revenue Agency, right to the appeals’ stage at the Tax Court of Canada (and beyond, to the Federal Court of Appeal).

Her attraction to taxation law commenced in law school, as a Research Assistant for a taxation law professor. She excelled in the Master of Law (Taxation) full-time program at Osgoode Hall Law School, York University. Angela continued to take taxation law courses post-LLM in a desire to complete all taxation law courses offered, which she has now accomplished. Combining her academic writing during the advanced degree and afterward, she has written 16 academic final papers in varied areas of taxation law. Since September 2015, she has attended over 100 continuing professional development programs in the area of taxation law.

Angela has worked at two law firms, which practice exclusively in taxation law, in Kitchener and Toronto; the former firm dealing with income tax, commodity tax, Canada Pension Plan, and Employment Insurance matters and the latter firm dealing with commodity tax and customs’ matters.  She has experience in CRA Tip Reports, Voluntary Disclosures, Taxpayer Relief Applications, T1 Adjustments, Requests for Loss Determinations, etc.  Angela has had a broad-based exposure to taxation issues, including, but not limited to, derivative assessments (under s. 160 of the Income Tax Act and s. 325 of the Excise Tax Act, and director’s liability); placement agencies, and the distinction between independent contractors and employees; fictitious losses; business expenses; income versus capital; house-flipping; employee benefits; net worth assessments; tax donation schemes; Schedule V and VI of the Excise Tax Act dealing with exemptions and zero-rated supplies, respectively; input tax credits; small supplier issues; and matters under the Tobacco Tax Act, Retail Sales Tax Act, and Land Transfer Tax Act (with respect to Non-Resident Speculation Tax).

Prior to her career in taxation law, Angela spent nearly 7 years in civil litigation, and domestic family law and child protection. During this time, she worked at two law firms in the Niagara Region, operated her own practice in domestic family law and child protection, and worked as in-house legal counsel at the Children’s Aid Society of the Niagara Region.  She brings to Rogerson Law Group extensive litigation experience.

Among other memberships, she is currently the Vice-Chair of the Taxation Law Section of the (Canadian) Ontario Bar Association and the first woman to hold this position. This will be her fourth year on the Executive Committee.

While lawyers are usually considered to be quite linear and right-brained, Angela has a creative side, too; she has recently taken courses to upgrade her French language skills, took Italian and Spanish during her undergraduate studies, and is learning to paint in watercolour.

Upcoming Engagements

Angela will be organizing and chairing the upcoming After Summer program for the Taxation Law Section of the (Canadian) Ontario Bar Association on September 3, 2019 and co-organizing and co-chairing a joint program with the Real Estate/Estates/Elder Law Sections of the Canadian (Ontario) Bar Association in November 2019 (Title and Date TBD).

Languages:

• Working knowledge of French and Italian