Taxation & Tax Litigation
Taxation covers a broad range of services ranging from advice as to whether a particular tax applies in a particular set of circumstances, to structuring an individual’s personal affairs or a commercial agreement or corporate structure to minimize future tax, to dealing with tax assessments and disputes once they have arisen, to tax litigation in the event that a resolution cannot be reached between the taxpayer and the taxing authority.
The following is a list of some of the topics and issues with which we can help:
- Advice as to a reassessment or disallowance of specified items and the realistic options;
- Response and/or negotiation with respect to a proposed disallowance or reassessment;
- The filing of a notice of objection in the event that the taxing authority cannot be convinced of a reasonable position at first instance;
- Appealing to the Tax Court of Canada in the event that your objection is unsuccessful;
- Requesting a waiver of penalties, regular and gross negligence penalties, before the Tax Court of Canada;
- Preparation of a taxpayer relief application (previously referred to as a fairness application), for relief from interest;
- The preparation and submission of a voluntary disclosure with respect to income not previously declared;
- Incorporation to obtain the lower small business rate of tax, permit income splitting between spouses and other family members, and other benefits of incorporation (other than limited liability);
- Corporate restructuring to reduce overall tax liability and assist with distribution of income to shareholders;
- Arranging for rollovers (transfers of assets on a capital gains tax deferred basis);
- Relief from seizure and other tax enforcement and negotiation of payment plans;
- Incorporation of offshore corporations in low tax and no tax jurisdictions;
- Assistance with respect to tax treaties, withholding tax and other similar issues;
- Assistance with preparation of annual information returns for registered charities (form 3010);
- Compliance consulting for registered charities (Canada);
- Threatened revocation of charitable status and imposition of revocation tax;
- Personal liability of directors for GST and HST; and
- Personal liability of directors for unpaid source deductions/employee tax deductions.
Please feel free to call us with respect to a preliminary assessment on the above or other tax issues.