We represent clients through every stage of a dispute with the CRA or provincial tax authorities. This includes managing audits, framing objections with detailed written submissions, and advancing appeals before the Tax Court of Canada and other relevant tribunals. Accountants and lawyers can be confident that once a file requires tax dispute work, their client will have counsel dedicated solely to tax disputes, with experience in both federal and provincial and municipal matters.

When a client faces investigation or prosecution for tax evasion, specialized representation is critical. We defend against search warrants, compelled examinations, and charges laid by the Crown, combining tax law expertise with courtroom skill. Entrusting a client to us ensures that they are guided through the process strategically and rigorously, from the investigative stage through trial.

The Voluntary Disclosures Program allows taxpayers to correct past non-compliance while reducing exposure to penalties and prosecution. We assess eligibility under current CRA policy, prepare comprehensive submissions, and negotiate with the CRA to secure acceptance. Accountants often involve us when a client’s fact pattern is complex, involves offshore holdings, or presents potential criminal exposure - circumstances where legal representation is essential to protect the client.

The CRA, provincial. and municipal tax authorities exercise broad powers once an assessment is issued, even while a dispute is unresolved. Clients may face liens, garnishments, or seizures that disrupt their business or personal finances. We intervene to negotiate relief, challenge improper collection measures, and bring matters before the courts when necessary. By referring the client at this stage, professionals ensure collection issues are managed by counsel who regularly deal with enforcement issues.

Some disputes require remedies outside the conventional channels. We pursue fairness applications to reduce penalties and interest, remission applications in extraordinary circumstances, and Ombudsman involvement where service failures are involved. We also bring judicial reviews in the Federal Court to challenge unreasonable CRA decisions and obtain rectification orders from BC’s superior court when documents have created unintended tax results. These tools allow us to resolve complex client issues that extend beyond standard dispute processes.