Domestic Tax Law

Strategic tax counsel for the Canadian federal and Nova Scotia provincial tax regimes, and steady representation when the Canada Revenue Agency comes calling.

Scope of work

• Tax planning & corporate structuring
• CRA audits, reviews & reassessments
• Notices of Objection & Tax Court appeals
• GST / HST and indirect tax matters
• Voluntary Disclosures Program filings
• Director’s liability & collections defence
• Owner-manager & small-business tax

There is little in modern life more draining than the prospect of a tax liability. The Canada Revenue Agency performs an essential public function, yet the taxpayers it contacts for audit or collection too often experience the process as one that begins from a posture of suspicion. Most people and small businesses are simply ill-equipped to make a powerful federal agency stop, listen, and understand the actual facts of their affairs.

Our work in this area is grounded in a principle Canadian law already recognizes: the Taxpayer Bill of Rights. Taxpayers have the right to be treated professionally, courteously, and fairly; the right to complete and accurate information; the right to have the law applied consistently; and the right to lodge a service complaint and request a formal review. When the CRA loses sight of those rights, we are there to insist on them across the audit, appeals, and collections functions alike.

The firm advises on tax matters at both ends of the lifecycle. On the planning side, we structure corporations, partnerships, and transactions to be tax-efficient and defensible under the Income Tax Act and the Excise Tax Act. On the dispute side, we respond to audit queries, prepare and file Notices of Objection, and litigate appeals before the Tax Court of Canada and, where necessary, the Federal Court of Appeal. Where past filings need to be corrected, the Voluntary Disclosures Program can offer relief from penalties and prosecution if it is approached correctly and promptly.

Tax defence requires diligence, technical knowledge, and judgment in equal measure. Working alongside accountants and other advisors, we aim to either resist an assessment outright or resolve liability and penalties on terms a client can live with, and just as importantly to redirect the conversation away from the agency’s default of assessing and collecting at almost any cost.