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Tax law

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:

  1. Advice as to a reassessment or disallowance of specified items and the realistic options;
  2. Response and/or negotiation with respect to a proposed disallowance or reassessment;
  3. The filing of a notice of objection in the event that the taxing authority cannot be convinced of a reasonable position at first instance;
  4. Appealing to the Tax Court of Canada in the event that your objection is unsuccessful;
  5. Requesting a waiver of penalties, regular and gross negligence penalties, before the Tax Court of Canada;
  6. Preparation of a taxpayer relief application (previously referred to as a fairness application), for relief from interest;
  7. The preparation and submission of a voluntary disclosure with respect to income not previously declared;
  8. 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);
  9. Corporate restructuring to reduce overall tax liability and assist with distribution of income to shareholders;
  10. Arranging for rollovers (transfers of assets on a capital gains tax deferred basis);
  11. Relief from seizure and other tax enforcement and negotiation of payment plans;
  12. Incorporation of offshore corporations in low tax and no tax jurisdictions;
  13. Assistance with respect to tax treaties, withholding tax and other similar issues;
  14. Assistance with preparation of annual information returns for registered charities (form 3010);
  15. Compliance consulting for registered charities (Canada);
  16. Threatened revocation of charitable status and imposition of revocation tax;
  17. Personal liability of directors for GST and HST; and
  18. 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.