Taxation Law & Policy
Jonathan Bright is a tax lawyer and a student of taxation law and policy,
with a healthy dose of musical creativity on the side.
Jonathan is a graduate of the Juris Doctor program at the University of Toronto Faculty of Law. During his time there, he was a member of several successful Moot Court teams, including the 2012 championship team at the Davies Corporate/Securities Moot, and was an Editor-in-Chief of the Journal of International Law & International Relations. He was called to the Ontario Bar in June, 2014.
In 2010 Jonathan was awarded the degree of Master of Public Policy by the University of Toronto School of Public Policy & Governance and, in 2008, he was awarded a Bachelor of Arts by University College at the University of Toronto. Jonathan also attended the University of Toronto Schools from 1998 through 2004.
Present & Future
Jonathan is an associate in the tax group at the Toronto office of McMillan LLP, where he maintains a general corporate income tax practice. Prior to joining McMillan, Jonathan was an associate in the Toronto office of a national boutique tax law firm.
At the conclusion of his legal studies at the University of Toronto, Jonathan was awarded the Nathan Strauss, Q.C., Essay Prize for his examination of the portrayal of the legal profession in the arts; he also recently published an article on the viability of the OECD's multilateral instrument in the Canadian Tax Journal. Jonathan is currently working on a study of complexity in income tax policy and legislative design, and hopes to publish his conclusions by early 2018.
State Sovereignty and the Multilateral Instrument
Canadian Tax Journal, Volume 64 Issue 2
Discussion of the viability of the OECD's proposed multilateral instrument to amend member states' bilateral treaties, in which the authors argue that to achieve its goals, the instrument will need to be more than a one-time undertaking, and that concerns over the potential cession of state sovereignty to an international body may limit the instrument's effectiveness in the long run. [With Ian Bradley].
George Weston and the Characterization of Gains on Derivatives
Canadian Tax Journal, Volume 63 Issue 3
Discussion of the Tax Court of Canada's decision in George Weston Limited v. The Queen, in which the authors argue that the decision may make it significantly more difficult in future cases for the CRA to argue that certain new, innovative, and dynamic hedging arrangements are not related to an underlying capital asset, and that the courts may instead take a broader approach in assessing the linkages between creative hedging techniques and the relevant underlying asset. [With Steven Baum].
Public Policy & Governance Review, Vol. 3, Iss. 1
Discussion of policy problems inherent to the corporate residency requirements of the Canada Income Tax Act.