• Robert Santia tax-driven corporate reorganizations

Robert Santia B.A., J.D., LL.M


Bar Admission

Ontario, 2016

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Robert Santia brings a characteristically unique enthusiasm to everything he does and nowhere is this more evident than in the practice of law. One need only spend five minutes speaking with Robert about tax and estate planning to understand that Robert deeply enjoys his work.  

Robert practices as an associate lawyer in Robins Appleby’s Tax group. Robert works primarily with individuals, private businesses and their advisors to help achieve personal, business and financial objectives, including minimizing tax liabilities by developing and implementing practical and creative strategies that are tailored to meet the needs of the client.

Robert has extensive experience designing and executing a wide array of tax-driven corporate reorganizations, as well as advising on the use of domestic and offshore trusts for tax and estate planning purposes. Robert has developed a particular expertise in assisting high net-worth families in structuring their holdings to minimize tax that arises in connection with generational succession and death. In connection with his interest in these subjects, Robert has written a number of articles for Canadian and international tax publications and has spoken on these topics for various professional and educational associations.

Outside of the office, Robert enjoys spending time with his wife and daughter, cooking and learning foreign languages. In addition to his native English, Robert speaks fluent French, Italian, Spanish and Portuguese, as well as conversational Mandarin Chinese. 

Selected Publications

• “Interpreting ‘Tends to Indicate Misuse or Abuse’ or: How I Stopped Worrying About Economic Substance and Learned to Embrace Principles of Statutory Interpretation”
Tax for the Owner-Manager, Vol. 24, No. 2 (Canadian Tax Foundation), April, 2024.

“Select Issues for Deemed Resident Trusts”
Tax Profile (Wolters Kluwer), July, 2022.

“TCC Bursts Post Mortem Pipeline”
Canadian Tax Focus, Vol. 12, No. 2 (Canadian Tax Foundation), May, 2022.

“Canada's New Tax on Split Income Regime is Here to Stay” 
co-authored with Rachel Blumenfeld, The International Comparative Legal Guide to Private Client 2019 (Global Legal Group), January, 2019.

“Revisiting Planning for Private Company Shareholders after July 2017”
Canadian Tax Journal, Vol. 22, No. 2 (Canadian Tax Foundation), June, 2018.

"Trust Issues: An Update" 
co-authored with Ed Esposto, Report of Proceedings of the Sixty-Ninth Tax Conference, 2017 Conference Report, (Toronto: Canadian Tax Foundation, 2018), 28:1-40.

“New Voluntary Disclosure Program Discloses No Intention to Attract Volunteers” 
co-authored with Jack Bernstein and Angelo Gentile, Tax Notes International, September 11, 2017

“Multi-Jurisdictional Pre-Immigration Planning” 
co-authored with Rachel Blumenfeld, Ed Powles, Emma-Jane Weider, Alon Kaplan, Lyat Eyal, Stanley A. Barg and Eric Dorsch, in Trusts & Trustees, ttx118, Oxford University Press, September, 2017.

“Court Backs Move of Trust’s Residency,” 
co-authored with Pavle Levkovic, OBA Business Beat (Ontario Bar Association), July, 2017.

“Tax-Efficient Gifting to Canadians by Non-Residents: Some Issues and Considerations” 
co-authored with Rachel Blumenfeld, New York State Bar Association and Society of Trust and Estate Practitioners’ (STEP) 13th Annual International Estate Planning Institute, March, 2017.

“The Income Tax Act and Estate Planning: The Law of Unintended Consequences”
co-authored with Ed Esposto, Ontario Bar Association Annual Institute – Trusts and Estates Law Section, February, 2017.

“Principal Residence Exemption: Trusts and Non-Residents”
 co-authored with Jack Bernstein, Canadian Tax Highlights, Vol. 25, No. 1 (Canadian Tax Foundation), January, 2017.

“Discretionary Trusts and Ontario Net Family Property” 

co-authored with Nathan Wright, Canadian Tax Focus, Vol. 6, No. 4 (Canadian Tax Foundation), November, 2016.

Selected Speaking Engagements

“Fundamental Steps and Considerations in an Estate Freeze to Minimize Tax on Death”
Co-chair, Osgoode Hall Professional Development, Taxation in Wills and Estates, Webcast, February 21, 2023.

“Practical Advice for Tackling Challenging Planning Issues: Death of a Shareholder – Introduction to the Problem of Double Taxation”
Speaker, Ontario Bar Association, Trusts and Estates Law/Young Lawyers Division Program, Toronto ON, November 4, 2019.

“Speed Mentoring: Practical Advice on Succeeding as a Young Tax Lawyer”
Speaker, Ontario Bar Association, Taxation Law Program, Toronto ON, October 1, 2019.

“Taxation of Private Corporations: An Overview of Tax Considerations 
During Life and at Death”
Speaker, Canadian Tax Foundation, Toronto Young Practitioners Tax Conference, Toronto ON, June 17, 2019.


  • Education
  • Memberships
  • Awards and Recognition
  • Community Involvement
  • Chartered Professional Accountants of Canada (CPA Canada), In-Depth Tax Course, Levels I to III, 2021
  • University of British Columbia, LL.M (Taxation), 2015
  • University of Toronto, J.D., 2014
  • McGill University, B.A., 2010
  • Law Society of Ontario (LSO)
  • Ontario Bar Association
  • Canadian Bar Association
  • Canadian Tax Foundation
  • 2022, 2023 and 2024 Editions of Best Lawyers in Canada: Ones to Watch
  • LL.M in Taxation Award, University of British Columbia
  • Past Co-Chair, Osgoode Hall Law School Intensive Program in Wills & Estates (Taxation in Wills and Estates)