We represent clients at all stages of disputes, from controlling the flow of information during audits to presenting persuasive arguments in court, appeals and alternative dispute resolution proceedings.
Our objective is to resolve tax disputes as early in the process as possible and without the need for litigation.
Canadian tax dispute resolution
We can help clients and their accountants manage the audit process, the Canada Revenue Agency (CRA) internal appeals process, the provincial appeals division process, and we can represent clients at all levels of court – from the provincial courts to the Supreme Court of Canada.
When litigation is unavoidable, or chosen as a tactical alternative, our clients’ cases are handled by litigators who are complete tax lawyers, experienced in transactional planning as well as litigation. In contrast, certain firms attempt to litigate tax cases using attorneys who do not deal regularly with the subtle nuances of the tax law.
Although we do not act as trial counsel in criminal cases, we represent clients in tax fraud investigations or where there is a concern that tax fraud might be asserted, with the objective of avoiding criminal indictment.
International tax dispute resolution
We act for clients facing foreign tax audits or disputes. This includes managing their relationship with foreign tax authorities and providing a solid defense of their tax position. Issues range from determining whether a Canadian company has a taxable presence in a foreign country, to the international allocation of profits among related entities in a corporate group.