Christopher J. Montes

Chris is the co-managing partner of the Calgary office of Felesky Flynn LLP. He focuses on corporate and international tax planning and frequently represents clients at the audit, objection and appeal stages of tax disputes.

With close to 15 years of tax law experience, Chris is a natural leader who can bring together the right team of tax professionals to solve complex problems effectively and efficiently.

Chris often writes and presents for top tax associations and has taught international tax law at the University of Calgary Faculty of Law. He has also testified as an expert witness on matters of Canadian income tax law.

Credentials

Called to the Alberta Bar, 2011
Called to the Ontario Bar, 2009
Master of Laws (LL.M), University of Cambridge (First Class Honours)
Bachelor of Laws (LL.B), Osgoode Hall Law School, York University (Silver Medallist)
Bachelor of Commerce (B.Comm), University of Calgary (Gold Medallist)
Executive Education Program in Transfer Pricing, Duke University
CPA Canada In-Depth Tax Course (Levels I, II & III); In-Depth International Tax Course; In-Depth Transfer Pricing Course

Memberships & Affiliations

Member, Law Society of Alberta
Member, Law Society of Ontario
Member, Canadian Bar Association
Member, Canadian Tax Foundation
Past President and Past Director, Canadian Petroleum Tax Society
Member, Calgary Bar Association
Member, International Fiscal Association
Past Member, Management Advisory Council, Haskayne School of Business, University of Calgary
Former Chair, Executive Committee, Canadian Bar Association (Alberta South), Taxation (Non-Specialists) Section

Publications & Presentations

“Mind the Gap: FABI Relief Falls Short for CCPCs,” International Tax Highlights, Volume 3, Number 4, November 2024 (co-authored)
Instructor, International Tax Law, University of Calgary, 2024
“Mandatory Disclosure Rules: Commercial Considerations”, Tax Executives Institute (Calgary Chapter) Breakfast, October 2023 (co-presented)
“Mandatory Disclosure Rules”, Canadian Petroleum Tax Society Fall Lecture Series, October 2023 (co-presented)
Moderator of Q&A Session with the Hon. Jason Kenney, “Will Government Policy Help or Hurt Alberta’s Economic Future?”, Canadian Petroleum Tax Society – Annual Conference, June 2023
Moderator, “US Tax Developments”, International Fiscal Association (Canada) Conference, May 2023
“Recent Trends and Select Issues in International Transactions,” Tax Executives Institute (Canada) Annual Conference, May 2023
“Retroactive Effects of the Proposed Amendment to the Definition of “Relevant Tax Factor,” International Tax Highlights, Volume 2, Number 2, May 2023
Instructor, International Tax Law, University of Calgary, 2023
Instructor, International Tax Law, University of Calgary, 2022
Moderator, “Recent Canadian and International Developments”, International Fiscal Association (Canada) Conference, May 2022
“Foreign Transactions: Mergers, Wind-ups, Liquidations: How Should They Be Interpreted for Purposes of the ITA?,” Workshop at the Canadian Tax Foundation’s Seventy-Third Annual Tax Conference, November 2021 (co-presented)
“Hot Audit Topics,” Canadian Petroleum Tax Society Fall Lecture Series, October 2021
Instructor, International Tax Law, University of Calgary, 2021
“Focus on Fundamentals – Tax Residency”, 2020 Canadian Tax Foundation’s Young Practitioner Focus Conference, September 2020
“A Transfer Pricing Case Study: Maximizing Success Throughout the Planning and Dispute Process”, TEI Canada Webinar, May 28, 2020 (co-presented)
YIN Rapporteur, “Current Issues and Considerations in Cross-Border Financing”, 2020 Joint Meeting of the US and Canada Branches of the International Fiscal Association, February 2020
Instructor, International Tax Law, University of Calgary, 2019
“Recharacterization under Section 247: Still an Exceptional Approach”, 2018 Canadian Tax Foundation’s Seventieth Annual Tax Conference, November 2018 (co-authored and co-presented)
“The Changing Tax Landscape for Foreign Investment into Canada,” Canadian Petroleum Tax Society – Monthly Networking Luncheon, March 2018 (co-presented)
“A Detailed Review of the Back-to-Back Loan Rules,” 2016 Canadian Tax Foundation’s Sixty-Eighth Annual Tax Conference (co-authored and co-presented)
YIN Rapporteur, “US Developments and Implications for Canadian Tax Planning,” International Fiscal Association (Canada) Conference, May 2016
“Update on Subsection 55(2),” Canadian Bar Association (Alberta), Taxation Specialists Group Presentation, November 2015
YIN Rapporteur, “US Developments and Implications for Canadian Tax Planning,” International Fiscal Association (Canada) Conference, May 2015
“Federal Budget 2015: Proposed Amendments to Section 55,” Canadian Petroleum Tax Society – Monthly Networking Luncheon, May 2015
“Butterfly Transactions: A Review and Update,” Canadian Petroleum Tax Society – Monthly Networking Luncheon, November 2014
“Recent Tax Avoidance Jurisprudence,” Canadian Petroleum Tax Society – Annual Conference, June 2014; conference paper published in the Canadian Petroleum Tax Journal, vol. 27, 2014-2
“Defending Against Common CRA Assertions,” Canadian Petroleum Tax Society – Fall Lecture Series, October 2013
“The 2013 Budget and Sommerer,” Canadian Tax Highlights, Volume 21, Number 5, May 2013
“Current Canadian Tax Cases,” Canadian Bar Association (Alberta), Taxation Non-Specialists Group Presentation, November 1, 2012
“Habitual Abode Not Always Where the Heart Is,” Tax for the Owner-Manager, Vol. 12, No. 3, 5-6, 2012
“Recent Developments in the Taxation of Trusts,” Canadian Bar Association (Alberta), Taxation Non-Specialists Group Presentation, April 5, 2012
“Let the Buyer (and Seller) Beware: The FCA’s Decision in Daishowa,” Tax for the Owner-Manager, Vol. 12, No. 1, 6-7, 2012
“Debt Forgiveness in a Partnership Context”, Tax for the Owner-Manager, Vol. 11, No. 2, 11-12, 2011
“Practical Issues Encountered When Winding-Up a Corporation”, 2011 Prairie Provinces Tax Conference, (Toronto: Canadian Tax Foundation, 2011), 11:1-37 (co-authored and co-presented)

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Christopher J. Montes

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