If you need to take your matter to court, it means that you have exhausted all your other avenues. At this juncture, you need to have a clear appreciation of your case. Why haven’t you been able to resolve it? What is at the core of the CRA or Revenu Quebec’s position? What do you have on your end to counter?
Tax litigation requires a unique skillset acquired through years of experience. Each issue needs to be addressed by carefully analysing the text of the law within the broader context of the legislation, the relevant jurisprudence and the specific facts of the case.
Communicate with us to schedule a consultation. We can provide you with an assessment of your position upfront so you know the strength of your case and the options that are available to you.
Some of the tax issues that we litigated:
- GST/QST
- Deductibility of Business Expenses
- Unreported Income / Net Worth Assessments
- Withholding Taxes
- Employment Benefits
- Shareholder Benefits
- Residency
- Employee vs. Independent Contractor
- Income vs. Capital Gain
- Heath and Welfare Trusts
- SR&ED
- Tax Shelters
- Sham
- Interest Deductibility
- ITCs
- Debt Forgiveness
- Source of Income
- Director Liability
- GAAR
- Non-Arm’s Length Transfers
- Attribution Rules
- Penalties (Including Gross Negligence Penalties)
- Foreign Reporting Requirements (T1135)
- Judicial Review of Administrative Decisions