Ministry of Finance and Ministry of Revenue

Office Snapshot

  • Location: Toronto
  • Lawyers: 35
  • Articling Students: 1
  • Summer Law Students: 2
  • Types of Law: Aboriginal, Access & Privacy, Administrative, Civil, Commercial, Contract, Corporate, Government Financing, Insurance, Pensions, Real Property, Securities, Tax

Who we are

Counsel working with the Legal Services Branch of the Ministry of Finance (MOF) and Ministry of Revenue (MOR) provide legal support to:

  • MOF, which is responsible for serving the public interest by supporting a strong economic, fiscal and investment climate for Ontario
  • MOR, which is responsible for administering and collecting tax and non-tax revenues.

We also provide advice regarding the administration of provincial legislation that is under the responsibility of the Ministers of Finance and Revenue.  This advice covers the areas of taxation, non-tax revenue, securities, pensions, provincial borrowing, debt management, fiscal and financial operations, electricity restructuring and privacy of information, among other areas. Our office provides advice on some of the most important issues facing government today.

What we do

A broad variety of legal work is performed at our office, including legislative drafting, tax, litigation, prosecutions, corporate and commercial law, securities law and pension law.


Lawyers in the government financing group frequently work on complex transactions, including:

  • Providing advice relating to the sale of Provincial debt in the domestic and international capital markets
  • Drafting a variety of agreements including loan agreements and banking agreements
  • Preparing provincial guarantees
  • Providing advice relating to the financial service needs of other ministries, crown agencies and public bodies
  • Negotiating derivatives agreements
  • Providing legal advice in relation to the finances of Ontario, including the application of the Financial Administration Act and the Ministry of Treasury and Economics Act.


The tax practice group consists of both solicitors and litigators. Lawyers in the solicitors group provide advice to the Ministers of Finance and Revenue on a variety of tax issues and are the lawyers who are primarily involved in the annual Ontario budget process. Typical tasks include:

  • Providing clients with opinions in connection with the interpretation of provincial tax legislation, involving personal income and corporate taxes, commodity and sales, and municipal and education taxes
  • Drafting legislation for the Spring and Fall budget bills
  • Advising on the legislative process for the enactment of legislation, including the review of proposed legislation by Cabinet committees.

The litigation group is primarily involved with representing the Minister of Revenue in tax appeals, many of which involve issues that are novel. The group also assists in the collection of tax and non-tax revenue. Litigation tasks include:

  • Preparing replies, factums, and affidavits of documents
  • Conducting examinations for discovery
  • Making oral arguments at trial and appeal levels on actions and applications.


Our prosecutions group is located in Oshawa.  Lawyers in the group prosecute quasi-criminal offences under Ontario’s numerous tax statutes.


There are several other areas of law practised in our office that do not fit into the above categories, including pensions and insurance, freedom of information and protection of privacy, procurement, aboriginal, municipal and bankruptcy and insolvency.

Our major cases

Counsel at MOF and MOR frequently have the opportunity to work on complex, high-profile transactions. Some of the more recent transactions include:

  • Loans to the auto sector
  • Asset backed commercial paper restructuring
  • Ontario Budget and associated budget bills
  • Proposed harmonization of the GST and PST
  • Reform of the pension benefits regime
  • A successful appeal to the Supreme Court of Canada with respect to the application of the Mining Tax Act to complex hedging transactions (Placer Dome v. Minister of Finance).

What students do


Articling students at MOF and MOR are provided with an excellent opportunity to assist counsel with the broad range of law practised in our office.  The articling student program typically consists of three primary rotations – tax litigation and tax solicitor’s work, government financing, and prosecutions. The student will also assist counsel with other types of work available as required.  The articling program allows for a degree of flexibility, and can be tailored to suit the particular interests of the articling student.  During the prosecutions rotation, the student will be stationed in the Oshawa office from four to six weeks.

Some of the typical tasks that an articling student would assist counsel with are:


  • Assisting lawyers with domestic and international bond transactions
  • Drafting agreements and guarantees.


  • Researching and drafting memoranda on various tax issues
  • Attending briefings of senior management in relation to proposed legislative amendments
  • Attending “lock-up” on the day that the Ontario budget is released.


  • Assisting lawyers with trial preparation including drafting replies, facta and affidavits of documents
  • Accompanying lawyers to examinations for discovery and trials.


  • Speaking to matters at Provincial Offences Court.

Summer Law

Summer law students will receive excellent exposure to the various practice areas in our branch. The duration of the student’s time is spent in the Toronto office performing tasks similar to those listed above for articling students. There is no prosecutions rotation for summer students. Students who are interested in articling at the Ministry of Finance and the Ministry of Revenue are encouraged to apply for a summer law position.

Why choose us

Students at MOF and MOR gain a breadth of experience, and are presented with opportunities to work on complex financial transactions and tax issues in addition to tax appeals and prosecutions. Students are exposed to the legislative process and government decision-making touching on all areas of government activity. Students also have opportunities to be involved with the annual spring budget and issues related to the regulation of the insurance, pension, securities and electricity industries.

The articling experience at MOF and MOR allows students latitude to explore their particular interests while being exposed to diverse work. The practical and varied experience gained in both litigation and solicitor’s work provides an excellent foundation for future opportunities, not only with the Ministries of Finance and Revenue, but with other government ministries and the private sector.

Students will be involved with current economic issues and will find their experience at MOF and MOR to be rewarding and well-rounded.

Many of our counsel have moved on to senior positions within the Ministry of the Attorney General, other areas of government and private practice. However, the varied activities and the opportunities for professional growth within the branch, have historically led to a high retention rate.

Contact us

Michael Waterston
Senior Counsel

Nicole Symeonides