LN TAX AND TRADE NEWSLETTER |September 2026
1. EDITOR'S NOTEWelcome to the September edition of the LN Tax and Trade Newsletter. This newsletter comes out against the backdrop of discussions at the federal and the provincial level of governments on how to incentivize Canada’s economy. In this newsletter, our own Allan Ritchie contributes to this debate on the much-needed reform of the roll-over of capital gains from the sale of a qualified small business. In this edition, our co-founder Sandy Nixon is featured in the celebrated Vanity Fair Proust Questionnaire. Althea Yip provides valuable information to an advisor whose client undertaking a sale of their business. Althea will also be leading a webinar discussion on Thursday, October 22nd from noon to 1 p.m. EST and the link to register is found here. The recent federal court of appeal case of Zeifmans LLP is reviewed by Lily Modir. In Canada, unlike lawyers, accountants do not hold solicitor-client privilege or confidentiality protection on advice rendered to their clients. In Zeifmans the CRA issued a Request for Information on the accounting firm of the Ghermezian family. The Ghermezian family have since 2014 refused to provide the CRA with information on their offshore trusts. The review of the Federal Court of Appeal decision by our associate Lily Modir makes an interesting read and reminds the reader of the broad audit powers contained by the CRA. Dylan Gervais discusses the GST/HST decision Medsleep which discusses whether a facility services to a physician is a taxable supply where such service is integral to the service provided by the physician to their patient. |
Loopstra Nixon’s Tax and Trade group continues to monitor Canadian-U.S. trade relations and will continue to provide updates on significant events. Loopstra Nixon is available to assist businesses in navigating the rapidly evolving trade and regulatory landscape. Zachary Swannell provides us with an update. 2. THE WRITE-OFFCanada's tax code tells its best entrepreneurs to stop building
![]() Allan Ritchie, Partner In my tax and M&A practice, I watch the same story play out again and again. An entrepreneur sells the business they spent fifteen or twenty years building. They pay their tax. And then, instead of putting that capital back to work, they park it in a portfolio of GICs and index funds and call it a day. |
Canada does have a rollover mechanism on the books. Section 44.1 of the Income Tax Act allows an individual to defer the capital gain on the sale of eligible small business corporation shares, provided the proceeds are reinvested in shares of another eligible small business. Parliament recently improved it. Bill C-15 received royal assent this year, raising the asset ceiling for eligible corporations and giving sellers until the end of the following calendar year to reinvest, instead of the previous 120 days. That sounds like progress, and in a narrow sense it is. But the mechanism still misses the point. To qualify, the reinvestment has to be in newly issued treasury shares, meaning you subscribe for stock in a business that is effectively starting from scratch. If you want to do what most experienced operators actually do, which is buy an existing private company, take control of it, and turn it around or scale it up, none of that qualifies for relief. The tool is built for the passive angel investor writing a cheque into a startup, not for the operator who wants to run the next one. That is backwards. It's precisely the entrepreneur who is prepared to take control of an existing enterprise, put their own capital and expertise on the line, and grow it, who should be getting the incentive to keep reinvesting. Instead, the rule pushes that money toward the sidelines the moment a deal closes, which is where I see so much of it end up. Contrast this with the United States. American entrepreneurs and investors have access to a materially more generous regime for qualified small business stock. Under section 1202 of the Internal Revenue Code, gains on qualifying stock can be excluded from tax entirely, not just deferred, up to a cap that runs into the tens of millions of dollars following the 2025 expansion of the rules. There's also a rollover provision, section 1045, that lets a seller defer gain by reinvesting in new qualifying stock within sixty days. |
To be fair, that mechanism has similar structural limits to our own, since it also requires newly issued shares in a qualifying small business rather than the purchase of an existing company. But the scale of relief on offer is not close. Canada shelters roughly $1.275 million over a lifetime through the Lifetime Capital Gains Exemption. The American regime can shelter many multiples of that on a single transaction, and it can be used again on the next one. The Americans also have a template worth borrowing from a completely different part of their tax code. Under the like-kind exchange rules for real estate, an investor can defer gain by rolling proceeds into another existing property, not just a freshly built one. There's no principled reason a similar approach couldn't apply to the sale of a private operating business. If a seller reinvests within a reasonable window, say two years, into another active Canadian business, whether that means starting one from scratch or acquiring an existing enterprise and taking control of it, the policy goal is the same either way: keep the capital and the entrepreneur in the game. Ottawa doesn't need to invent something new here. It needs to widen a door that is already half open. Expand section 44.1 so the reinvestment can take the form of acquiring an existing private business, particularly where the individual is taking control of it, not just subscribing for new stock in a startup. Give it a real window, two years is reasonable. And stop treating the lifetime exemption as the only lever in the toolkit. Every year that a proven operator's capital sits parked instead of redeployed is a year we lose the compounding effect of that person's judgment, relationships and appetite for risk. We built a tax system that rewards them for building once and then getting out of the way. We should be building one that rewards them for doing it again. |
3. M&A TAXConnecting the Dots: Tax issue spotting for professional advisors.
Althea Yip, Partner One of the realities of modern professional practice is that very few significant client matters belong to a single advisor anymore. A business sale may involve corporate counsel, tax advisors, lenders, wealth advisors, valuation experts and insurance professionals. A succession plan can quickly raise issues relating to corporate structures, trusts, family dynamics, retirement planning and intergenerational wealth transfer. Even a refinancing transaction may lead to discussions about shareholder arrangements, estate planning or compensation structures. Most clients today have no shortage of advisors. The lawyer focuses on legal risk. The banker focuses on financing. The accountant focuses on financial reporting and compliance. The wealth advisor focuses on preserving and growing wealth. What is often missing is someone who connects the dots. That does not mean every advisor needs to become an expert in every discipline. It does, however, mean that professionals should develop enough awareness to recognize when an issue that appears legal, financial, banking or investment-related may have implications elsewhere. Tax is one of the most common examples. Clients rarely seek advice because they think they have a tax issue. They call because they want to sell a business, transfer a cottage to their children, bring a new investor into a company, purchase real estate, restructure debt or plan for retirement. The tax issues are usually hiding inside the broader objective. |
As a result, one of the most useful skills any professional advisor can develop is the ability to recognize when a matter may have tax implications and when further investigation is warranted. The good news is that tax issue spotting is often less complicated than people assume. Most significant tax issues arise from a relatively small number of common situations. When Should Tax Alarm Bells Start Ringing?One useful rule of thumb is that tax issues often arise when something of value is changing hands. That may seem obvious when a client is selling a business or a piece of real estate. What is less obvious is that the same principle applies to many transactions that do not initially look like tax matters. A founder wants to transfer shares to a child who is joining the family business. A parent wants to add a child to title for a cottage. A shareholder wants to move assets into a corporation. Business partners want to reorganize ownership before bringing in a new investor. Each of those transactions involves a transfer of value. Once value is being transferred, tax consequences are often not far behind. Capital gains, attribution rules, land transfer tax, GST/HST, valuation issues and other considerations can suddenly become relevant. Another common trigger is a change in ownership. Many clients view ownership changes as straightforward business or family decisions. From a tax perspective, however, ownership matters a great deal. Whenever someone is being added as an owner, removed as an owner, gifted property, issued shares or admitted into a business venture, there is usually merit in asking whether tax consequences have been considered. That does not necessarily mean there is a problem. It simply means the transaction deserves a closer look. A third category involves clients choosing between different structures. Experienced advisors have all heard questions such as: "Should I incorporate?" "Should I buy this property personally or through a corporation?" "Do I need a holding company?" "Would a trust make sense?" |
Clients often view these as business or legal questions. In reality, they are usually tax questions as much as anything else. Different ownership structures can produce dramatically different results over time, particularly when income is earned, assets increase in value, financing is obtained, or the business is eventually sold. Cross-border matters are another area where advisors should immediately slow down and ask additional questions. When Canada is the only country involved, many professionals can comfortably identify when specialist advice may be required. Once another jurisdiction enters the picture, matters become less predictable. A shareholder moves to the United States. A Canadian corporation hires a U.S.-based employee. Foreign investors become involved. An entrepreneur expands operations into another country. What appeared to be an employment matter, financing matter or corporate matter can suddenly involve residency issues, withholding obligations, tax treaties and foreign reporting requirements. Even where no obvious tax issue exists, the presence of a border should generally prompt someone to ask whether tax advice is required.
Tax Issue Spotting Is Not Just About Avoiding ProblemsOne misconception is that tax issue spotting is simply about avoiding unpleasant surprises. Certainly, identifying risk is important. However, some of the greatest value comes from recognizing opportunities. Many client objectives can be achieved in several different ways. The challenge is that once a particular path has been chosen and implemented, alternative options may no longer be available. A business sale provides a good example. By the time a letter of intent has been signed and transaction documents are being negotiated, certain planning opportunities may already be lost. A reorganization that could have been implemented before a sale may not be available afterwards. An estate freeze is generally more effective before value accumulates than after. |
The same is true for estate freezes, corporate reorganizations, trust planning and numerous other strategies that must be considered before the transaction occurs rather than afterwards. The difference between average advice and exceptional advice is often not technical knowledge. It is timing. The advisor who identifies a tax issue six months before closing can create opportunities. The advisor who identifies it the day before closing may simply be delivering bad news.
Knowing When to Call for HelpPerhaps the most important skill is recognizing when a matter falls outside one's expertise. Clients are best served when their advisors understand both the limits of their own knowledge and the value that other professionals can bring to the table. The banker does not need to become a tax lawyer. The lawyer does not need to become a wealth advisor. The accountant does not need to become a commercial lender. What each professional should develop, however, is an awareness of the circumstances that should prompt further inquiry. If ownership is changing, if value is being transferred, if there is a choice of structure, if a significant transaction is occurring, if another country is involved, or if a major life or business event is taking place, tax considerations are likely part of the discussion. The most successful advisors are often not those who know the most answers. They are the ones who recognize the important questions early enough that the right specialists can be brought into the conversation. That is ultimately what tax issue spotting is about: not becoming a tax expert, but developing the judgment to recognize when tax may matter and ensuring that opportunities and risks are identified before they become irreversible.
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4. AUDIT POWERS OF THE CRACRA requirements for information: The Federal Court of Appeal confirms broad audit powers.
Lily Modir, Associate The Canada Revenue Agency (“CRA”) has broad powers to require information from third parties in connection with tax audits. A recent decision of the Federal Court of Appeal (“FCA”) confirms both the breadth of those powers and the importance of challenging a requirement for information (“RFI”) at the appropriate stage. In Canada (National Revenue) v. Zeifmans LLP, 2026 FCA 147, the FCA reversed the Federal Court’s decision and ordered an accounting firm to comply with an RFI issued by the Minister of National Revenue (the “Minister”). The decision provides important guidance for accounting firms, law firms, financial institutions and other professional advisers that hold records relating to clients under audit.BackgroundZeifmans LLP, a Toronto accounting firm, was the authorized representative for members of the Ghermezian family, whom the CRA had been auditing under its Related Party Initiative since at least 2014. Between 2015 and 2019, the CRA issued numerous demands for documents and information directly to family members and related entities, but most of the demanded material was never provided. After years of non-compliance, the Minister issued an RFI directly to Zeifmans under subsection 231.2(1) of the Income Tax Act (the “Act”). The RFI sought six years of records relating to the named taxpayers and to “entities owned, operated, controlled or otherwise connected” to them. The requested information included emails and correspondence, accounting records and working papers, bank statements, tax-planning documents, step memoranda, loan documents, client profiles, and other records. The family’s own battles with the CRA continued in parallel. In February 2019, days after the Zeifmans RFI was issued, the Minister filed six applications in the Federal Court to compel five family members and a related corporation to comply with the outstanding demands. The family’s judicial review challenges to their own RFIs were dismissed in 2020, and compliance orders were granted for the Minister’s applications in 2022, which were substantially upheld on appeal in 2023. The FCA further confirmed that the CRA’s audit powers extend to compelling taxpayers to provide information, not merely pre-existing documents. In 2024, the Supreme Court of Canada declined to hear the family’s appeal. |
Similarly, Zeifmans resisted compliance, contending that the RFI extended to unnamed persons and therefore required prior authorization from a Federal Court judge under subsection 231.2(2) of the Act. Zeifmans challenged the RFI by way of judicial review and was unsuccessful before the Federal Court in 2021 and again on appeal in 2022. Despite those decisions, Zeifmans did not produce the requested records. The Minister then applied to the Federal Court for a compliance order under section 231.7 of the Act. In a 2023 decision, the Federal Court dismissed the application. The Federal Court held that the evidentiary record was materially different from the record in the judicial review proceedings. In particular, new evidence established that some of the unnamed entities referred to in the RFI were themselves under audit. On that basis, the Federal Court concluded that prior judicial authorization was required and declined to order compliance. The Minister appealed. The FCA allowed the appeal and ordered Zeifmans to comply with the RFI.
Key takeaways from the decision.
The FCA focused on the purpose of the requirement, rather than simply on whose information might appear in the requested records. Where an RFI is issued for the purpose of investigating the tax compliance of named taxpayers, prior judicial authorization is not required merely because the records requested contain information about other, unnamed persons or entities. In Zeifmans, the evidence was consistent with the Minister’s position that the RFI was issued to obtain information about the named taxpayers under audit, not to verify compliance of the unnamed persons. The fact that the requested material might be used in the future for the audits of those unnamed persons did not establish that investigating their compliance was a purpose of the RFI. The FCA therefore rejected the Federal Court’s conclusion that the existence of audits involving some of the unnamed entities meant that prior judicial authorization had been required.
The FCA did, however, expressly reject the Minister’s argument that authorization can be dispensed with whenever the “primary” purpose of an RFI is to audit the named taxpayers. If any genuine purpose of an RFI is to verify the tax compliance of unnamed persons, prior judicial authorization is required. The key question, therefore, is not simply whose information may ultimately appear in the records. It is whether verifying that person’s tax compliance was a purpose for which the RFI was issued. |
2. Broad requests are not necessarily invalidThe FCA also confirmed the breadth of the CRA’s information-gathering powers. An RFI does not have to identify precisely how every requested document will ultimately be used. The relevant statutory threshold is whether the information may be relevant to the administration or enforcement of the Act. Zeifmans argued that the RFI was impermissibly broad and vague, particularly because it extended to entities that were “otherwise connected” to the named taxpayers. The FCA rejected that argument. An RFI must be worded with sufficient precision to enable meaningful compliance by the recipient. Read together with the accompanying information sheet, the RFI was sufficiently clear to permit compliance. This does not mean that every broadly worded RFI will be enforceable. Where a recipient genuinely cannot determine what information is being requested, the appropriate response is to raise the issue with the CRA and seek clarification. That point was particularly relevant because Zeifmans had not sought clarification from the CRA about the meaning or scope of the disputed language, and the FCA considered that omission significant. The practical lesson is straightforward: uncertainty about an RFI should prompt a documented request for clarification, not simply non-compliance.
3. Professional partnerships are not insulated from the CRA's powersZeifmans also argued that the RFI was invalid because it was addressed to a partnership rather than a “person” within the meaning of subsection 231.2(1) of the Act. The FCA rejected that technical argument. Subsection 244(20) of the Act deems each member of a partnership to have been provided with notice where the notice was properly sent to the partnership. The issuance of the RFI in the name of the Zeifmans partnership (rather than in the names of its individual members) did not invalidate the RFI. For professional firms, the broader lesson is straightforward: being an accounting, legal or other professional partnership does not, by itself, place the firm outside the CRA’s information-gathering powers. Where a professional firm holds records that may be relevant to an audit, the fact that the firm itself is not the taxpayer under audit does not prevent the CRA from requiring production of those records.
4. There is no accountant-client privilegePrivilege was not a contested issue in Zeifmans, but the decision proceeds on a premise that professional advisors should not overlook. A compliance order under section 231.7 of the Act cannot require the production of information or documents protected by solicitor-client privilege. The protection, however, belongs solely to legal advice. Accordingly, communications between an accounting firm and its clients are typically not shielded from disclosure to the CRA.
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This would include accounting records, tax-planning advice, and working papers prepared by an accountant in the course of providing accounting or tax advice. In limited circumstances, solicitor-client privilege may extend to communications involving an accountant where the accountant is acting as an agent or representative of the client for the purpose of obtaining legal advice. In Zeifmans, no claim of solicitor-client privilege was advanced, and the accounting firm’s records were therefore entirely within the CRA’s reach. The decision serves as a practical reminder for taxpayers and professional advisors dealing with sensitive tax-planning matters: information shared with an accountant in the course of obtaining accounting or tax advice is not, simply by virtue of its sensitive nature, shielded from disclosure to the CRA.
5. Challenge an RFI at the appropiate stageZeifmans had previously challenged the validity of the RFI by way of judicial review and had been unsuccessful. When the Minister later sought a compliance order, Zeifmans sought to raise substantially the same validity issues again. The FCA held that, in these circumstances, doing so constituted an abuse of process. Allowing a party to re-litigate issues that had already been determined would frustrate enforcement of the Act and bring the administration of justice into disrepute. The decision should not be read as establishing that an RFI can never be challenged in a compliance proceeding or that every issue raised in a later proceeding is automatically barred. The FCA’s conclusion was grounded in the particular procedural history of Zeifmans and the substantial overlap between the issues previously litigated and those raised again at the enforcement stage.
Conclusion
Canada (National Revenue) v. Zeifmans LLP is an important reminder of the breadth of the CRA’s information-gathering powers and the procedural risks associated with resisting an RFI. For accounting firms, law firms, financial institutions and other professional advisers, the message is practical: when an RFI arrives, assess it promptly, identify and document any objections, seek clarification where appropriate, and obtain legal advice before deciding not to comply. If your firm has received an RFI, we can review the request and advise on the validity and scope of the requirement, your obligations and the appropriate response to the CRA. |
5. GST/HST UPDATEDoctor-clinic fee sharing arrangements and GST/HST obligations: A case summary of MEDSLEEP INC.,2025 TCC 70
Dylan Gervais, Associate Why this case mattersThe MedSleep decision illustrates the Tax Court’s analysis for determining when a clinic is required to collect and remit GST/HST on amounts paid by physicians to the clinic. In particular, the decision is relevant for considering what constitutes a single compound supply between a clinic and physicians for determining whether GST/HST should be charged on facilities and services utilized in the course of providing services to patients.
Brief OverviewIn Medsleep Inc. v The King, 2025 TCC 70 the central issue was whether MedSleep Inc. (“MedSleep”) made a taxable supply to “Sleep Physicians” considering the fee sharing agreements between MedSleep and the Sleep Physicians. Under the fee sharing agreements, MedSleep retained a portion of the fees payable to Sleep Physicians. The Court concluded that MedSleep made a single compound supply of medical services which are exempt for the purposes of the ETA. Accordingly, the appeal was allowed and MedSleep was not required to collect and remit GST/HST in respect of supplies made by them to Sleep Physicians.
Factual BackgroundMedSleep operates clinics that offer diagnostic sleep tests to patients. In providing such diagnostic sleep tests, MedSleep contracts with various physicians specializing in sleep disorders (“Sleep Physicians”) and employs “administrative staff, registered practical nurses, registered polysomnographic technicians, scoring technicians, a director of education and medical directors.” At issue in the appeal is the portion of the fee charged to patients referred to as a professional fee relating to services performed by the Sleep Physicians. In all provinces where MedSleep operates, the professional fee is covered by the applicable Provincial Health Insurance Plan. Part of this professional fee is retained by the Sleep Physician and part is paid to MedSleep pursuant to agreements between MedSleep and Sleep Physicians (typically 80% is retained by Sleep Physicians and 20% is retained by MedSleep). Not at issue in this case is a “technical fee” for the overnight study itself which is conducted at MedSleep’s facilities and which is 100% retained by MedSleep.
The Court's Analysis: Applying the Three-Part test from River Cree Resort Limited Partnership.In reaching its conclusion, the Court considered the three-part analysis set out in River Cree Resort Limited Partnership v Her Majesty The Queen, 2022 TCC 45 for determining the nature of the supply made to patients: . |
On the first part of the test, the Court concluded the services constituted an end to end sleep study journey. The Court looked at what services were provided, considering the full suite of services provided to patients as of the services. The Court rejected the respondent’s arguments that Medsleep made a supply to Sleep Physicians constituting a “package of administrative, technical, marketing, referral and corporate services.” In so finding, the Court respected the relationship between MedSleep and Sleep Physicians which was documented in agreements containing a fee sharing arrangement. The Court reasoned that the specific services provided by MedSleep and Sleep Physicians cannot be usefully or realistically separated. On the second part of the test, the medical sleep services provided in tandem with the Sleep Physicians services was considered a single compound supply where the Court again rejected the Respondent’s arguments. In reaching this conclusion, the Court found there was no evidence of a separate supply being made to physicians and, using a common sense approach, the Sleep Physicians and MedSleep would not be able to provide their services to patients without the other. On the third part of the test, the analysis looked at the predominant element of the supply which in the present case was the supply of medical sleep services which the Court found constitutes an exempt supply for which GST/HST need not be remitted. As a separate consideration, despite that a single compound exempt supply was made for which there is no obligation to collect and remit GST/HST, the Court also explained that the Sleep Physicians were not a “recipient” as defined in subsection 123(1) of the Excise Tax Act. The analysis used for determining there was a single compound supply made by MedSleep where the only supply was made to patients was generally determinative in finding Sleep Physicians were not “recipients”. Therefore, the Court concluded MedSleep did not make a taxable supply to Sleep Physicians and was not required to collect and remit GST/HST on amounts paid to MedSleep by Sleep Physicians. Key takeaways: Relationship structure mattersThe overall relationships between clinic, physician and patients and the fee-sharing structure were determinative of the GST/HST consequences in this case. Failing to properly record agreements with respect to fee-sharing or providing services in such a structure that does not align with providing a single compound supply to patients could result in unintended GST/HST consequences. GST/HST are not levied on many healthcare services because these are not considered a commercial activity and are GST/HST exempt. Where a clinic collects GST/HST from physicians who do not collect GST/HST on their services, the physicians would be forced to absorb the GST/HST paid by them as they would not be able to claim input tax credits for GST/HST paid in such circumstances. As a further general concern, a retroactive and unexpected finding that a clinic failed to collect and remit GST/HST could result in devastating consequences based on liability for GST/HST unremitted.
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6. TRADE UPDATELN trade update: U.S. Counter-Tariffs on Canada
Zachary Swannell, Associate In response to Canada’s counter-tariffs that went into effect on September 8th, 2026, President Trump announced, on the same date, new counter tariffs on an expanded list of Canadian goods, as well as a prohibition on the import of certain Canadian products into the US. The additional Canadian goods subject to counter-tariff measures include:
President Trump’s announcement also included prohibitions on the import of some Canadian goods into the U.S., including:
The modifications to existing U.S. counter tariffs are effective September 15th, 2026, and the import bans go into effect on September 29th, 2026. Notably, President Trump has relied on Section 338 of the US Tariff Act of 1930 to impose tariffs on Canada during the recent trade conflict. Section 338 authorizes the imposition of tariffs on countries that engage in discriminatory or unfair trade practices in dealing with the United States. When this latest round of US counter-tariffs and import bans were announced on September 8th, President Trump characterized Canada’s late August retaliatory tariffs on US dairy, steel, and agricultural equipment products as discriminatory. It remains to be seen whether President Trump’s use of Section 338 will be challenged.
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7. THE PROUST QUESTIONNARE[In each issue, a member of the firm takes on the celebrated Vanity Fair Proust Questionnaire. This issue: J. A. Sandy Nixon.
J.A. Sandy Nixon. 1.What is your idea of perfect happiness? Skiing the glades on a powder day. 2. What is your greatest fear? Retirement. 3. What is the trait you most deplore in yourself? No forgiveness gene. 4.What is the trait you most deplore in others ? Arrogance. 5. Which living person do you most admire? Chuck Loopstra. 6. What is your greatest extravagance? The money pit, that is my cottage. 7. What is your current state of mind? Always the same/ looking forward. 8. What do you consider the most overrated virtue? Too complicated to figure out. 9. On what occasion do you lie? I have been known to embellish the facts when negotiating but I see that as part of deal making. 10. What do you most dislike about your appearance? A forced smile. 11. Which living person do you most despise? Right now that would be DJT. 12. What is the quality you most like in a man? Accountability. 13. What is the quality you most like in a woman? Assertiveness.
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14. Which words or phrases do you most overuse? Totally stuck on this one. 15. What or who is the greatest love of your life? My wife of 55 years. It was love at first sight for me and I told her I was going to marry her on our first date ( she just smiled at me). 16. When and where were you happiest? First day of University at Laurier. It was like I was let out of jail. 17. Which talent would you most like to have? To play the piano. Was forced to take lessons and hated it but love nothing more now than to listen to piano jazz. 18. If you could change one thing about yourself, what would it be? Run faster and jump higher. 19. What do you consider your greatest achievement? Aside from my illustrious career as a lawyer, I was the very first athlete from Laurier University to receive “All Canadian” recognition in 1969. 20. If you were to die and come back as a person or a thing, what would it be? An eagle sounds good. 21. Where would you most like to live? Not Rexdale. 22. . What is your most treasured possession? Not really into possessions. 23. What do you regard as the lowest depth of misery? Anxiety. 24. What is your favorite occupation? Never dreamed of being a lawyer and I only went to law school because I wasn’t ready to go out and work after university but it turns out it suits my personality quite well. Maybe it’s all the Presbyterian ministers in my bloodlines. |
25. What is your most marked characteristic? Passion. 26. What do you most value in your friends? Camaraderie. 27. Who are your favorite writers? Patrick O’Brien ( Master and Commander series). Best use of the English language I have ever read. 28. Who is your hero of fiction? Richard Sharpe. Main character in Bernard Cornwell’s Sharpe series of novels. 29. Which historical figure do you most identify with? Robert the Bruce. 30. Who are your heroes in real life? Anyone fighting for their life as we go around this crazy world at the moment. 31. What are your favorite names? No favourites. 32. . What is it that you most dislike? Drama in the office... 33. What is your greatest regret? None comes to mind. Just living the dream. 34. How would you like to die? No good choices here except maybe in my sleep. 35. What is your motto? Let’s get the job done. |

