Tax Dispute Resolution

The lawyers on our Tax Dispute Resolution Team advise and support individual and corporate clients through all stages of a tax dispute — from audit to objection and through all levels of court. At every stage we help our clients to understand their rights, to navigate the complex legal and procedural landscape, and to reach the right outcome.

Our lawyers represent individuals, small businesses, national and multinational corporations, partnerships, estates and trusts in disputes arising under federal and provincial taxation statutes and international tax treaties and agreements, including disputes relating to the following issues:

• specific and general anti-avoidance rule issues;
• residency status;
• income vs. capital;
• taxable vs. exempt supplies;
• tax credit claims and denials;
• directors’ liability;
• reassessments beyond the normal reassessment period;
• gross negligence and other penalties; and
• fleet tax compliance, including under IFTA.

Our lawyers have significant experience in successful appeals at the federal and provincial level, including in the Tax Court of Canada. Still, our approach is not strictly adversarial; we strive to work with the Canada Revenue Agency, the Department of Justice, and provincial finance authorities to effectively negotiate an informal resolution wherever possible.

Whether domestic or international matters in the public or private sectors, our lawyers have extensive experience in:

• supporting clients throughout the entire audit process;
• helping clients to respond to tax collection and other enforcement actions;
• responding to proposal letters and requests for information;
• filing objections, and applying for extensions of time to object;
• assisting with voluntary disclosures, taxpayer relief requests, and requests for remission;
• representing clients in applications for rectification, rescission, and other related relief;
• representing clients in appeals, applications for judicial review, and civil actions;
• negotiating settlements with the tax authorities and Department of Justice counsel; and
• appearing before all levels of provincial and federal court, including the Tax Court of Canada, the Federal Court, the Federal Court of Appeal, the provincial superior courts and courts of appeal, and the Supreme Court of Canada.

We also handle issues of risk assessment for our clients with a view to minimizing their risk exposure and empowering them to make informed tax planning decisions.

Recognizing that tax disputes and litigation can involve many different areas of law, we take a collaborative approach by engaging other members of our Firm as needed to effectively negotiate, settle and deliver cost-effective results.