CRA audits, reassessments, voluntary disclosures, and Tax Court appeals are not accounting problems. They are legal problems. Get tax counsel before you reply to the letter.
Personal and corporate audits, GST/HST audits, scope letters, requirement letters, audit defence strategy.
Notice of Objection within 90 days, Appeals Division submissions, settlement and waiver decisions.
Informal and General Procedure, pleadings, discoveries, settlement, trial, appeals to FCA.
VDP applications, foreign income, undeclared revenue, unfiled returns. No-name pre-disclosure consultations.
Residency status determination, treaty tie-breakers, departure tax, deemed dispositions.
T1135 disclosures, missed reporting, voluntary correction strategy, FBAR coordination for US persons.
Reorganisations, butterflies, section 85 rollovers, paid-up capital planning, surplus distributions.
Deemed dispositions on death, post-mortem planning, family trusts, 21-year deemed disposition planning.
Do not call CRA to negotiate before reading the letter carefully. Audit letters, requirement letters under section 231, and statutory demands have different responses. A tax lawyer triages the letter, identifies the actual ask, manages disclosure, and protects solicitor-client privilege where applicable. Many self-represented taxpayers volunteer information that worsens their position. A lawyer prevents that.
After a reassessment, taxpayers have 90 days to file a Notice of Objection (one year for individuals on some matters with extension). Miss the window and the reassessment stands. The objection submission is the chance to put the legal and factual position on the record. A strong objection narrative often resolves files at the Appeals Division without needing Tax Court.
The Voluntary Disclosure Program allows taxpayers to come forward and correct prior tax filings without prosecution and with potential interest relief. Strict eligibility: voluntary, complete, involves a penalty or potential criminal exposure, more than one year overdue. The program tightened in 2018 with a two-track system. Pre-disclosure no-name consultations remain available. Solicitor-client privilege protects pre-application analysis, which is often essential.
Tax Court of Canada hears appeals of CRA reassessments under the Income Tax Act and Excise Tax Act. Federal Court hears judicial review applications challenging the exercise of discretion by the Minister, such as denied taxpayer relief. The right court depends on what you are challenging. The wrong choice can be fatal.
Tax lawyers typically charge hourly with retainers, with senior counsel running $500 to $1,000 per hour. Some files run on fixed fees, particularly voluntary disclosures. Tax disputes are often economically rational to fight: the savings on a successful objection or appeal frequently exceed legal fees by orders of magnitude.
Possibly not. Extensions of time are available within one year of the original deadline if the taxpayer can show reasonable grounds and a bona fide intention to object. Beyond one year, the reassessment is final unless judicial review is available.
A successful VDP application provides protection from prosecution and from gross negligence penalties on the disclosed matters. It does not eliminate the tax owing or the interest in full. Eligibility is strict.
Both, on different work. Accountants prepare returns and run compliance. Tax lawyers handle disputes, audits, voluntary disclosures, court, and where privilege matters. For complex matters they work together.
Yes. CRA has broad collection powers including requirements to pay served on banks, employers, and customers, and the ability to register liens. Negotiation and stay applications can pause collection while disputes proceed.
Informal Procedure appeals often finish within 9 to 18 months. General Procedure appeals can run two to five years. Many settle before trial through the Appeals Division or pre-trial negotiation.
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