Michelle Moriartey *



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Michelle is a partner in the Tax Group and leads the tax litigation practice at Farris LLP. Michelle has extensive experience in all aspects of tax litigation and dispute resolution, including representing clients in disputes with the Canada Revenue Agency (CRA) and the Ministry of Finance, from the audit and objection stages to appeals before the courts. Michelle regularly appears on tax matters before the Tax Court of Canada, the Federal Court of Canada, the Federal Court of Appeal, and all levels of courts in British Columbia.

Michelle also resolves tax problems through other means, including voluntary disclosures, taxpayer relief requests, rectification and rescission proceedings and remission applications.

Michelle advises clients in respect of a wide range of Canadian tax issues, including tax avoidance, real property taxes (speculation tax, PTT and Empty Homes Tax), residence for tax purposes, real estate dispositions, employee and shareholder benefits, taxation of trusts and estates, RRSPs and TFSAs, offshore tax compliance, and GST.

Before joining Farris, Michelle worked for a boutique tax firm in downtown Vancouver. Prior to that, Michelle served as a Judicial Clerk at the Federal Court of Appeal and then practiced for four years with the tax group of an international law firm.

  • Member of the Law Society of British Columbia
  • Member of the Canadian Bar Association
  • Member of the Canadian Tax Foundation
  • The Best Lawyers in Canada (2024)
  • Lexpert Leading Lawyers in Canada (2024)
  • Lexpert Leading Finance and M&A Lawyers (2024)
  • Lexpert Leading Lawyers in Canada (Corporate Tax, 2023)
  • “Judicial Review of CRA Decisions Post-Vavilov: What’s Working, What’s Not, and Where Change is Needed”, Tax Disputes in Canada: The Path Forward (Canadian Tax Foundation: 2022).
  • “Audit Management 101”, PBLI Conference: When the CRA Cometh: Audits & Appeals (2021).
  • “Administrative Law for Tax Advocates”, Panel Discussion with Tim Fitzsimmons and John Sorenson at the Canadian Tax Foundation National Tax Conference (2020).
  • “Case Law Update”, PBLI Conference: Managing Risk in Tax Planning (2020).
  • “Dispositions of Real Estate”, PBLI Conference: Tax Fundamentals for Real Estate Transactions (2019), co-presented with Laura Peach.
  • “Repeated Failure-to-File Penalty: Scope Narrowed”, Canadian Tax Focus Newsletter (Canadian Tax Foundation: 2017).
  • “Judges Panel”, co-presented with Pooja Mihailovich, 2018 National Tax Conference.
  • “Best practices when representing taxpayers in the CRA’s new audit regime”, co-presented with Alistair Campbell and Shane Onufrechuk, 2018 B.C. Tax Conference.
  • “Recent Tax Cases”, presented with Lee-Lynn Gan (KPMG LLP) at the 2015 B.C. Tax Conference.
  • “Section 160: Recent Developments and Issues”, presented to the CBA B.C. Branch, Taxation Subsection on May 27, 2015.
  • “TCC Expert Witness Rules: Proposals for Change” (2013) vol. 3, no. 1 Canadian Tax Focus, 8-9.
  • “Current Cases”, presented with Andrew Majawa (Dept. of Justice) at the 2010 B.C. Tax Conference.
  • “Northland Properties: An Interesting Perspective on Onus of Proof”, CCH Tax Topics, July 22, 2010.
  • “Part-Time CCPCs Again” (2009) 17:5 Canadian Tax Highlights 6-7, co-written with Joel Nitikman.
  • “Amount Received by Shareholders from Foreign Corporations in the Course of Winding-Up”, CCH Tax Topics, April 17, 2008.
  • Case Comment on CGU Holdings Canada Ltd. v. The Queen, co-written with Joel Nitikman and Gordon Chu, (2008), vol. 56, no. 2 Canadian Tax Journal, 469-501.
  • Mutual Fire Insurance Company of British Columbia v British Columbia, 2021 BCSC 626.
  • 5551928 Manitoba Ltd. v. Canada (Attorney General), 2019 BCCA 376.