Whether you are facing an audit, a reassessment, an unfiled return, or a tax dispute that has escalated beyond your control — the difference between resolution and catastrophe is almost always the quality of the legal strategy applied in the first 30 days. We provide that strategy.
Solicitor-Client Privilege Applies · Available Across Canada · CRA Audit Defence · Tax Court Representation
What changes the moment CRA contacts you
The Canada Revenue Agency has extraordinary powers — the authority to freeze bank accounts, garnish wages, place liens on property, and pursue directors personally for corporate tax debts. Most Canadians do not discover the full scope of these powers until they are already being exercised against them. By that point, the window for the most effective legal strategies has already begun to close.
Tax law in Canada is extraordinarily complex — the Income Tax Act alone runs to thousands of pages, with interpretive guidance, administrative policy, and case law layered on top. A reassessment that appears straightforward on its face may involve objection rights, fairness provisions, voluntary disclosures, or Tax Court proceedings that require specialist legal knowledge to navigate effectively.
The most expensive mistake our clients make is waiting. They wait to respond to the CRA. They wait to file returns. They wait to seek advice. By the time the situation becomes impossible to ignore, penalties have accrued, options have narrowed, and what could have been resolved quietly has become a formal dispute. We fix that — but earlier is always better.
"I received a reassessment for $340,000. I thought it was over. My tax lawyer had it reduced to $12,000 through a Notice of Objection I didn't even know existed."
How we resolve tax problems
When the CRA selects you for audit — income tax, GST/HST, payroll, or SR&ED — we manage every aspect of the process. We communicate with auditors on your behalf, control the flow of information, and protect your rights throughout. Most audits end better with counsel than without.
A reassessment is not a final answer. You have the right to object — and the objection process is where the most significant reductions are won. We analyse every reassessment, build the legal and factual record, and argue your position before the CRA Appeals Division and the Tax Court of Canada.
Unfiled returns. Unreported income. Offshore assets. The CRA's Voluntary Disclosure Program offers protection from prosecution and penalty relief — but only if approached correctly, with complete and properly structured disclosures. We have guided hundreds of clients through this process.
When the CRA will not move and the stakes are too high to accept their position, we go to court. We represent clients before the Tax Court of Canada and the Federal Court of Appeal — with the preparation, the precedents, and the courtroom discipline that wins.
Holding company structures, estate freezes, corporate reorganisations, transfer pricing, and dividend planning — we design tax-efficient structures that protect corporate wealth, facilitate succession, and withstand CRA scrutiny.
Canadians working abroad. Foreign nationals investing in Canada. U.S. citizens with Canadian assets. We navigate the treaty network, residency determinations, foreign reporting requirements, and FBAR obligations that define cross-border tax compliance.
How a tax dispute unfolds — and where we intervene
The CRA issues an assessment, reassessment, or audit request. This is the moment to engage counsel — before you respond, before you provide documents, before you say anything. What you do in the first 30 days shapes everything that follows.
We analyse the CRA's position in full, review your records, identify the legal and factual weaknesses in their case, and build the strategy that will drive the best outcome — whether that is an objection, a disclosure, or a negotiated resolution.
We file your Notice of Objection or Voluntary Disclosure with precision — every fact supported, every legal argument positioned, every procedural requirement met. The objection stage resolves the majority of disputes before they reach the Tax Court.
CRA Appeals reviews your objection. We negotiate directly with the Appeals Officer, present supporting documentation and legal authority, and pursue every available avenue for reduction, cancellation, or settlement.
If the Appeals Division does not provide an acceptable resolution, we take your case to the Tax Court. We have the precedents, the technical preparation, and the courtroom experience to argue complex tax matters at the highest level.
Why tax law requires a specialist
The CRA employs thousands of auditors, investigators, and legal counsel — specialists whose entire careers are devoted to identifying tax liability and collecting it. When they audit you, they are not generalists. They are using targeted techniques, industry-specific benchmarks, and audit programs designed to maximise reassessments. Meeting that with a general practice lawyer or an accountant without tax litigation experience is bringing the wrong team to the most important game of your financial life.
We are tax lawyers — not accountants, not consultants, not generalist practitioners who handle tax files on the side. Everything we do falls within the scope of Canadian tax law — from the Income Tax Act to the Excise Tax Act to the tax treaties that govern your international obligations. That specialisation is what allows us to find the arguments that others miss, apply the provisions that others overlook, and achieve outcomes that others do not know are possible.
Every area of Canadian tax law
Your protection
Solicitor-client privilege is one of the most fundamental protections in Canadian law. When you speak with a tax lawyer, everything you disclose — your records, your decisions, your concerns, the full picture of your tax situation — is legally protected from disclosure to the CRA, to courts, and to any third party. That protection does not exist with accountants. It does not exist with tax consultants. It exists only with lawyers.
That distinction matters enormously when you are facing an audit or a dispute. It means you can give us the complete, unvarnished picture — including the parts that worry you most — and we can build your defence around the full truth, rather than the partial picture that is safe to share with an unprotected advisor. Speak freely. We are bound to protect everything you tell us.
How you will feel when it is resolved
Tax disputes consume people. The unopened letters. The sleepless nights. The weight of a number that seems impossible to escape. Our clients do not just resolve their tax matters — they reclaim the mental space that was occupied by the problem. That is what resolution actually feels like.
The liability is settled. The returns are filed. The CRA file is closed. The number that followed you everywhere has been replaced by a number you can live with — or erased entirely.
Structures are in place. Future exposure is planned for. The CRA cannot surprise you again because we have made sure there is nothing left to find — and everything that exists is defensible.
You understand your tax position. You know what you owe, what you do not, and exactly why. That clarity is something most Canadians never have. Our clients do.
Common questions
Engage a tax lawyer before you respond. Anything you say or provide to the CRA can shape the entire course of the audit. We control the communication, decide what is produced and when, and protect your rights from the first interaction through to resolution.
Accountants prepare returns and provide tax compliance services. Tax lawyers provide legal advice, represent you in disputes with the CRA, file objections and appeals, litigate at the Tax Court of Canada — and your communications are protected by solicitor-client privilege, which does not apply to accountants.
For individuals, you generally have 90 days from the date on the Notice of Reassessment to file a Notice of Objection — or one year from the original filing deadline, whichever is later. For corporations, it is 90 days. Missing this window dramatically narrows your options. Contact us immediately if a reassessment has been issued.
Yes. The CRA has statutory collection powers that include freezing bank accounts, garnishing wages, registering liens on property, and pursuing directors personally for corporate tax debts. These powers can be exercised without going to court. Engaging counsel early is the most effective way to prevent or release such measures.
The CRA's Voluntary Disclosure Program (VDP) allows taxpayers to come forward with unreported income, unfiled returns, or undisclosed offshore assets in exchange for protection from prosecution and penalty relief. Eligibility depends on the disclosure being voluntary, complete, and made before the CRA contacts you. We assess every disclosure for eligibility before filing.
Yes. Solicitor-client privilege protects everything you disclose to your lawyer in the course of obtaining legal advice — from the CRA, from courts, and from any third party. This protection is fundamental to Canadian law and is one of the most important reasons to engage a lawyer rather than a non-legal advisor when facing a tax issue.
One confidential conversation. Solicitor-client privilege from the first sentence. A clear assessment of where you stand, what the CRA can and cannot do, and exactly how we will move your matter to resolution.
