Service Areas

Disputing Tax Assessments

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

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 CCRA 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 documents, such as a notice of objection;
• obtain information from the CCRA, including internal documents, memos, and notes used by the CCRA in support of its position;
• meet with CCRA 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. In such cases, we work closely with legal counsel in a support role on the client's behalf.