Randall Ian Schwartz

Randall Ian Schwartz

Partner, PwC Law LLP

Practice focus

Randy Schwartz is a tax partner in PwC Law LLP's Toronto office. Has over 25 years of experience in cross-border transactions in the energy, automotive, manufacturing, telecommunication and information technology industries. He advises on goods and services tax/harmonized sales tax, provincial sales taxes, value-added taxes, sales and use taxes, excise taxes and duties, valuation, tariff classification and international trade agreements.

Randy is currently Vice Chair of the National Commodity Tax, Customs and Trade Section of the Canadian Bar Association and a member of the GST Leaders' Forum. He also served as chair for the Commodity Tax Sub-Committee of the Canadian Electricity Association.

Randy is a recommended lawyer in the International Tax Review Indirect Tax Leaders Guide for four consecutive years since 2015 and a recommended lawyer in The Canadian Legal Lexpert® Directory.  He frequently writes and presents on indirect tax matters for various organizations including the Chartered Professional Accountants of Canada, Tax Executives Institute and Council on State Taxation. Prior to joining the Firm in October 2017, he was an indirect tax advisor at a leading international law firm.

Selected publications, presentations and articles

  • Co-Presenter, “The Drop Shipment Rules – Now That We Have Royal Assent, How Do They Work?”, CPA 2018 Commodity Tax Symposium, 16 October 2018.
  • Co-author, "The Proposed Amendments to the Drop Shipment Rules: Tidying Up and Filling the Gaps," Sales Tax, Customs and Trade, Vol. XIII, no.4, 2017  
  • Co-presenter, "Canadian Digital Economy Suppliers: Are You Ready for More Tax Compliance from Outside Canada?," CPA 2016 Commodity Tax Symposium, 24 October 2016
  • Presenter, "Canadian Value-added and Sales Tax Primer," Council on State Taxation (COST) Mid-West Regional State Tax Seminar, Ann Arbor, Michigan, August 2015
  • Co-presenter, "Customs, Cross Border VAT Importing/Exporting: Do's and Don'ts: Overview/Recovery of VAT in Canada," CGA Ontario 2014 Taxation Symposium, Toronto, March 2014
  • Presenter, "GST/HST and Commodity Tax Issues: Considerations for Non-Residents," 3rd Understanding Canada-US Taxation Seminar, Federated Press: Toronto, June 2013
  • Author, "Still Little Room for Compromise When it Comes to Settlements: CIBC World Markets v. The Queen," Sales and Use Tax, Vol. XII, no. 1 2012
  • Author, "British Columbia voters to decide on future of HST in the province," Tax Planning International, Volume 9, Number 6, June 2011
  • Author, "United Parcel Service - Reversed," GST & Commodity Tax, Vol. xxii, no. 6, July 2008

Professional affiliations

  • Law Society of Upper Canada - Member  
  • Canadian Bar Association - Member
  • Canadian Tax Foundation - Member


  • Global area of practice: Indirect Tax


  • Admission — Ontario—Canada (1991) - Education University of Toronto (LLB) (1989) - University of Michigan (Bachelor of Business Administration with High Distinction) (1986)