The Honourable Patrick J. Boyle is a former justice of theTax Court of Canada. He was appointed to the court in 2007 and served until his retirement in 2024. He served as acting associate chief justice following the 2021 retirement of Associate Chief JusticeLucie LaMarre until the December 2023 appointment of Associate Chief JusticeAnick Pelletier. He was a member of the court’s Rules Committee and chaired its Judicial Education Committee.[1][2] In 2014, Justice Boyle was named byEuromoney's ITRInternational Tax Review as one of the 25 most influential people in the tax world.[3]
Justice Boyle was born inVictoria, B.C., and has lived in Ottawa, Quebec City, Chicago and Washington, D.C. He did his undergraduate studies in chemical engineering atUniversity of Ottawa. He obtained his common Law degree atOsgoode Hall Law School (LL.B./JD 1980), and his Civil Law degree in French atUniversity of Ottawa (LL.Lsumma cum laude, 2011). He was called to the Bar of Ontario in 1982 after articling atGowling & Henderson in Ottawa.[1][2]
Boyle was associate and partner atFraser Milner Casgrain (nowDentons) in Toronto from 1982 to 2007, and seconded to the Federal Departments of Justice and Finance from 2000 to 2002.[1] His tax practice was focused on financial institutions and corporate transactions.[4][5] He was an accomplished tax litigator and an expert on the regulation of charities in Canada.[6][7][8]
At the time of his appointment, Boyle was vice-chair of theCanadian Bar Association's (CBA) National Tax Law Section, vice-chair of the CBA-CICA Joint Committee on Taxation, and on the editorial board ofWolters Kluwer'sCCH Canadian Tax Reporter.[2]
Prior to his appointment, he taught advanced tax atUniversity of Windsor Law School, served as special advisor on tax policy to the Department of Finance, and was a member of theCanada Revenue Agency's (CRA)GAAR Committee and itsTransfer Pricing Review Committee.[9][10] Boyle was governor of a university college, and he volunteered in a general counsel role to one of Canada's largest charities. He was on the board ofWorld Vision Canada.[11]
Justice Boyle has presented at numerous Canadian and international tax conferences, including conferences sponsored by theCanadian Tax Foundation, l’Association de Planification Fiscale et Financière, Tax Executives Institute, CRA,Department of Finance Canada, CBA,International Bar Association and the International Association of Tax Judges (IATJ). He was the Program Chair at the first two Assemblies of the IATJ in 2010 and 2011.[12]
In one judgement, Boyle quotedOscar Wilde on lying: "If a man is sufficiently unimaginative to produce evidence in support of a lie, he might just as well speak the truth at once".[13] In another, he incorrectly attributed toMonty Python a skit that should have been attributed toRobin Williams.[14][15]
Since his retirement from the Court, the former Justice Boyle is Of Counsel with KPMG Law in its Tax Law and Tax Litigation & Dispute Resolution practices.[16][17]