In the Canadian environment of high tax rates, complex tax rules, frequent change, and an aggressive approach by the CRA, the fact that Canadian taxpayers have disputes with the tax authorities is understandable and inevitable. We assist in resolving these disputes and represent clients with a well-researched defence of a position. Where the dispute is more serious, we will work closely with legal counsel if called for.

In tackling such an assignment, we:

• meet with the client to review the circumstances;
• review the taxpayer’s financial statements, tax returns, notices of assessment and reassessment, and the CRA correspondence, as well as any other relevant materials;
• give a preliminary opinion as to an appropriate defence and the chances of success;
• prepare any required official documents, such as a notice of objection;
• obtain information from the CRA, including internal documents, memos, and notes used by the CRA in support of its position;
• meet with the CRA representatives, in either the audit division or the appeals division, to present the taxpayer’s case; and
• negotiate a settlement when negotiation is called for.

If the dispute cannot be resolved in the appeals area and proceeds to court, or if the matter is particularly serious, the situation may be referred to legal counsel in the first instance. We work closely with legal counsel in a support role on the client’s behalf in such cases.