About the firm

Pariz Consulting Group Ltd. is a Toronto consulting firm that has focused on Canadian tax since 2015.

We work in two streams. For taxpayers, we provide tax planning and assistance with disputes with the Canada Revenue Agency (CRA), through a selection of fixed-fee services and full-service engagements. For lawyers, accountants, and other advisers, we provide tax research, transaction planning support, and dispute and litigation support behind the scenes.

We regularly work with lawyers, accountants, valuators, and other professionals in Canada and internationally, and make referrals as needed.

The tax wiki and the blog on this site are part of our work: an annotated Income Tax Act and a continuing record of case commentary.

Beyond tax, the firm advises owner-managed businesses on compliance and governance systems, on business structure, on the commercial side of starting, buying, or selling a business, and on automating recurring back-office work. These matters are taken on by enquiry and are not listed as services. The limits stated at the foot of this page apply to them equally.

About our principal

Sas Tullo

Principal, Pariz Consulting Group Ltd.

Sas Tullo is a tax consultant and tax dispute professional with over 15 years of experience in Canadian taxation. He advises individuals, business owners, and fellow tax professionals on complex tax planning matters and on tax disputes with the Canada Revenue Agency.

His practice covers the full range of dispute resolution, from audits and objections through to Appeals Division negotiations and collections, working with litigation counsel where a matter proceeds to the Tax Court of Canada. On the planning side, he works with owner-managers and families on remuneration, reorganizations, succession, and the anti-avoidance rules that shape them.

B.Sc., B.Ed., M.A., LL.B./J.D. (UBC); LL.M., Ph.D. (exp.) (Osgoode Hall Law School); CPA In-Depth Tax (1, 2, 3); PC (Camosun)

Tax

• Answering Canadian Tax Questions: An Introduction to Tax Law Research, Osgoode Legal Studies Research Paper No. 30/2015 (2015). A second edition is in preparation. SSRN
• “Legitimate Expectations in Canada: Soft Law and Tax Administration” (with Lorne Sossin), in M. Groves and G. Weeks, eds., Legitimate Expectations in the Common Law World (Portland, OR: Hart Publishing, 2017). SSRN
• “Waivers of Limitation Periods in the Income Tax Act: Judicial Interpretations and Approaches”, Osgoode Legal Studies Research Paper No. 50/2014 (2014). SSRN
• “Tax Avoidance, Tax Evasion, and Tax Fairness: The Meaning of ‘Fair Share’ in International Corporate Income Taxation” (2015). SSRN
• “Fortuitous Victims: Some Tax Law Consequences of Ponzi Schemes” (with Jackson Taylor) (2014). SSRN
• “Death and Taxes: The Nature of a Deceased’s ‘Estate’, its Relationship to the Deceased, and Practical Implications for Reassessments” (2014). SSRN
• “Rethinking the Nature of Incorporeal Properties in International Taxation: A Theory of Removable and Non-Removable Incorporeal Properties”, paper presented at the 5th Annual Meeting of the Association for Law, Property and Society, University of British Columbia, May 2014. SSRN

Legal theory and other writing

• “Globalisation and Legal Scholarship: William Twining’s Call for Revolutionary Jurisprudence” (2013) 4:4 Transnational Legal Theory. SSRN
• Review of Institutionalized Reason: The Jurisprudence of Robert Alexy, Matthias Klatt, ed. (Oxford University Press, 2012) (2013) 4:1 Transnational Legal Theory 126. SSRN
• “Too Fat for Society? William Bogart and Regulating Obesity? Government, Society and Questions of Health” (2014) 52:1 Osgoode Hall Law Journal. SSRN
• “The Perpetual Pursuit of Sharing and Caring: Thomas Kleven’s Equitable Sharing as a Guide for Legal Actors Chasing Meaningful Democracy”, Osgoode Legal Studies Research Paper No. 10/2015 (2015). SSRN
• “Comments and Feedback on ‘Growing Up: Ontario’s Condominium Communities Enter a New Era’, Condominium Act Review: Stage Two Solutions Report” (with Sujoy Chatterjee), Osgoode Legal Studies Research Paper No. 48/2014 (2014). SSRN

The tax wiki on this site applies the research method set out in Answering Canadian Tax Questions to each provision of the Income Tax Act.