H. Michael Dolson

With an emphasis on corporate and international tax planning, Mike advises public corporations, owner-managers, First Nations and public sector entities on income tax and GST matters.

Mike holds a Bachelor of Laws degree and Master of Laws degree in United States taxation, possessing a deep level of knowledge on cross-border business structures. He brings over 12 years of experience to his role as a partner in Toronto and is ranked by Canadian Lexpert® and The Best Lawyers in Canada™ as a leading tax lawyer and was named the Best Lawyers® 2022 Tax Law “Lawyer of the Year” in Edmonton. He currently serves as a Governor of the Canadian Tax Foundation.

An intellectual and inquisitive thinker, Mike’s mastery of tax law enhances dynamic outcomes for clients. As a talented researcher and writer, he spins complex tax jargon into engaging insights. Mike regularly contributes to reputed industry publications and is a former lecturer at the University of Alberta, where he taught corporate tax.

In his free time, he loves to indulge in fresh pasta at authentic Italian restaurants, while still staying sharp by working out and reading.

Credentials

Called to the Ontario Bar, 2020
LL.M (in Taxation – Executive Program), New York University, 2014
Called to the Alberta Bar, 2010
LL.B (with Distinction) (Area of Concentration: Taxation), University of Western Ontario, 2009
In-Depth Tax Course (Parts I, II & III), CPA Canada

Memberships & Affiliations

Member, Canadian Bar Association
Member, Canadian Tax Foundation
Member, International Fiscal Association

Publications & Presentations

H. Michael Dolson and Siobhan A.M. Goguen, KC, “Emigration from Canada,” Report of Proceedings of the Seventy Fourth Annual Tax Conference, 2022 Annual Tax Conference, (Toronto: Canadian Tax Foundation, 2023)
H. Michael Dolson and Paul Lynch, “Navigating the New Reporting Rules,” in 2022 Ontario Tax Conference, (Toronto: Canadian Tax Foundation, 2022)
Michael Dolson and Anthony V. Strawson, “Legislative Amendments Affecting Charities,” Tax for the Owner-Manager, vol. 22, no. 4 (Canadian Tax Foundation), October 2022
“Tax Policy Issues Relevant to Captive Insurance Companies in Alberta,” (2022), vol. 15, no. 28 School of Public Policy Research Papers
H. Michael Dolson and Ryan W. Antonello, “FAPI: SCC Confirms Investment Business Interpretation,” Canadian Tax Focus, vol. 12, no. 1 (Canadian Tax Foundation), February 2022
H. Michael Dolson and Ryan W. Antonello, “The Continuing Saga of Bill C-208,” XVII(3) Corporate Structures and Groups (Thomson Reuters), 2021
“Nicole L. Tiessen Interior Design v. R.: Subsection 256(2.1) Reimagined,” XVII(2) Corporate Structures and Groups (Thomson Reuters), 2021
“Paletta: Straddles Can Work!” Canadian Tax Focus, vol. 11, no. 2 (Canadian Tax Foundation), May 2021
Ryan W. Antonello and H. Michael Dolson, “Vendor Held Harmless Where Property Sold to Tax-Motivated Arm’s-Length Buyer,” Canadian Tax Focus, vol. 11, no. 2 (Canadian Tax Foundation), May 2021

Byron S. Beswick and Michael Dolson, “International Tax for Owner-Managers,” in 2020 Definitive Guide to Owner-Manager Taxation Virtual Conference, (Toronto: Canadian Tax Foundation, 2020)
“AgraCity: Transfer Pricing Arrangement Not a Sham,” Canadian Tax Focus, vol. 10, no. 3 (Canadian Tax Foundation), August 2020
“FAPI: Investment Business Definition Clarified,” Canadian Tax Focus, vol. 10, no. 3 (Canadian Tax Foundation), August 2020
“Can a Tax Refund Be Paid to a Third Party? Section 116 and Foreclosures,” Canadian Tax Focus, vol. 10, no. 2 (Canadian Tax Foundation), May 2020
“Should Alberta Collect Its Own Personal Income Tax,” Canadian Tax Focus, vol. 10, no. 1 (Canadian Tax Foundation), February 2020
H. Michael Dolson, “A Comprehensive Review of Captive Insurance Companies,” Report of Proceedings of the Seventy First Annual Tax Conference, 2019 Annual Tax Conference, (Toronto: Canadian Tax Foundation, 2020)
H. Michael Dolson and Kyle A. Ross, “Windups, PUC Reductions, and GAAR: Implications of the CRA’s 2018 Commentary,” Tax for the Owner-Manager, vol. 19, no. 4 (Canadian Tax Foundation), October 2019
H. Michael Dolson, Kenneth Keung and Josh Kumar, “A Modern Overview of Specific Anti-Avoidance Rules,” Report of Proceedings of the Seventieth Annual Tax Conference, 2018 Annual Tax Conference, (Toronto: Canadian Tax Foundation, 2019)
“Democracy Requires Limits on Charities’ Political Activities,” Canadian Tax Focus, vol. 8, no. 4 (Canadian Tax Foundation), November 2018
“Toward Having One Tax Collector in Quebec,” Canadian Tax Focus, vol. 8, no. 3 (Canadian Tax Foundation), August 2018
H. Michael Dolson and Crystal L. Taylor, “Passive Investment Income: Past and Future,” 2018 Prairie Provinces Tax Conference, (Toronto: Canadian Tax Foundation, 2018)
“Time for Tax Reform?”, Law Now Magazine (Centre for Public Legal Education) (January/February 2018)
“Protect Ya Neck: Avoiding Tax Issues in Matrimonial Property Settlements,” Business Issues in Family Law Matters (Edmonton: Legal Education Society of Alberta, 2018)
“From Switzerland with Love: International Tax Espionage,” Canadian Tax Focus, vol. 7, no. 4 (Canadian Tax Foundation), November 2017
“The Netflix Tax: A Right Way and a Wrong Way”, Canadian Tax Focus, vol. 7, no. 3 (Canadian Tax Foundation), August 2017
“Proposed Income-Splitting Rules Could Land Outsized Hit on Small Businesses” The Globe and Mail (Report on Business), July 21, 2017
“The GAAR Post-Copthorne: Where We’ve Come From, and Current Applications,” 2017 Prairie Provinces Tax Conference, (Toronto: Canadian Tax Foundation, 2017)
“Taxing Robots: Easier Said Than Done”, Canadian Tax Focus, vol. 7, no. 2 (Canadian Tax Foundation), May 2017
“100th Anniversary of the Income Tax and the Taxation of First Nations,” Open Forum Blog (Canadian Tax Foundation), September 2016
“Exempt Surplus and TIEAs: A Bad Deal?”, Canadian Tax Focus, vol. 6, no. 3 (Canadian Tax Foundation), August 2016
“Daniels: Tax Changes for Non-Status Aboriginals”, Canadian Tax Highlights, vol. 24, no. 5 (Canadian Tax Foundation), May 2016
“Alberta To Continue To Run Its Own Corporate Income Tax”, Canadian Tax Focus, vol. 6, no. 1 (Canadian Tax Foundation), February 2016
“Policy Forum: Personal Services Businesses – A Two-Sided Policy Problem,” (2015), vol. 63, no. 3 Canadian Tax Journal, 705-716
“Canada’s Tax Rules Are Working Exactly As They Should” The Globe and Mail (Report on Business), October 9, 2015
“CRA Tax Debt Writeoffs”, Canadian Tax Highlights, vol. 23, no. 8 (Canadian Tax Foundation) (August 2015)
“What to Expect in Tax Adjudication”, Canadian Tax Highlights, vol. 23, no. 4 (Canadian Tax Foundation) (April 2015)
Trust Residence After Garron: Provincial Considerations,” (2014), vol. 62, no. 3 Canadian Tax Journal, 671-699
“Stop PSB Proliferation”, Canadian Tax Highlights, vol. 22, no. 9 (Canadian Tax Foundation) (September 2014)
“Some Thoughts on Legislative Intent and Statutory Interpretation,” Open Forum Blog (Canadian Tax Foundation), August 2014
“CRA Charities Audit Project – A Political Activity,” The Canadian Taxpayer, vol. XXXVI, no. 17 (Carswell), September 12, 2014
Jon D. Gilbert and H. Michael Dolson, “Accessing Surplus: What Works, What Doesn’t, What’s Left,” 2014 Prairie Provinces Tax Conference, (Toronto: Canadian Tax Foundation, 2014)
“Lost in the Flood: Dangers Associate with Inadequate Safekeeping of Tax Records,” Open Forum Blog (Canadian Tax Foundation), April 2014
“Is Income Tax Supposed to be ‘Fair’ – A Rejoinder,” Open Forum Blog (Canadian Tax Foundation), November, 2013
“Provincial Residency – Trusts,” 2013 Prairie Provinces Tax Conference, (Toronto: Canadian Tax Foundation, 2013)
“Subsection 55(2) and Section 84.1 Overview,” Tax Law Update, (Edmonton: Legal Education Society of Alberta, 2013)
Joyce A. Young and H. Michael Dolson, “Income Tax Consequences of Carrying on an Unrelated Business,” XV(1) Business Vehicles (Federated Press), 2013
“Cash for US Tax Whistleblowers”, Canadian Tax Highlights, vol. 20, no. 10 (Canadian Tax Foundation) (October 2012)
“The Tax Court of Canada: An Introduction,” Law Now Magazine (Centre for Public Legal Education) (September/October 2012) “Death of a Partner – Tax Consequences of an Unwritten Partnership Agreement,” XIV(2) Business Vehicles (Federated Press), 2011
“Kick-Starting Innovation by Increasing the Social Status of Scientists.” The Globe and Mail (Online Edition), November 24, 2011
“Stimulating Scientific Research Through Creative Policy,” The Canadian Taxpayer, vol. XXXIV, no. 1 (Carswell), January 6, 2011
Co-authored “Business Limit Allocation Do-Overs,” Tax For the Owner Manager, vol 11, no. 2 (Canadian Tax Foundation), July 2011
“Rectification and Rescission: S&D International Group Inc. v. Canada (Attorney General) (Alta. Q.B.),” XVIII Tax Litigation (Federated Press), 2011
Co-authored “The Amended Restricted Covenant Rules,” Tax for the Owner-Manager, vol. 10, no. 4 (Canadian Tax Foundation), October 2011
“New Rules for Professional Corporations,” XIII(2) Business Vehicles (Federated Press), 2010

Work with our experts

We're here to discover your tax law advantage.

Start today

People

H. Michael Dolson

People

H. Michael Dolson

Contact Info

Location

H. Michael Dolson

Contact Info

Location

Areas of Practice

Credentials

Memberships & Affiliations

Work with our experts

We're here to discover your tax law advantage.

Locations

Calgary

Edmonton

Saskatoon

Toronto

Navigation