Who are we? Experienced in both Tax Court litigation and Canada Revenue Agency ("CRA") settlement negotiation, our team of qualified Canadian tax lawyers and in-house accountants provide aggressive representation of taxpayers targeted by CRA for audit, assessment, and collection. We also serve as tax litigation counsel to other lawyers and accountants, referrals respected. What can we do for you? Typically, we assist our clients in dealing with: - CRA audits for corporate and personal income tax, GST, and payroll source deductions - Objections to CRA assessments - Appeals to the Tax Court of Canada and the Federal Court of Appeal - Structuring proposed transaction to legally minimize tax payable - Voluntary Disclosure / Tax Amnesty programs - Provincial audits for provincial sales taxes (PST) and workers' compensation accounts Combining accountants and lawyers in a team approach to tax disputes Many taxpayers rely on their accountants to help them with filing tax returns and to advise them on tax matters. An accountant is usually well-equipment to discover, organize and present information to the tax authorities. Many tax matters involve heavy number-crunching that only an experienced accountant can deal with effectively. Some accountants are extremely well-versed in tax law and can make cogent arguments acceptable by tax auditors, who are normally trained as accountants themselves. On the other hand, information you disclose to your accountant is not covered by solicitor-client privilege. Your accountant can be forced to release his or her files to the government. In those unfortunate situations, your accountant can become the government's best witness against you. If the amount of the federal taxes in dispute exceeds $12,000.00, an accountant cannot represent you in Tax Court. The tax authorities sometimes do not take seriously your accountants' threat to launch an appeal, and therefore may be less willing to be flexible in their negotiating position. Tax lawyers are trained to appreciate nuances in tax law and the rules of evidence, and therefore are often better suited to represent and advise you in an appeal process. The information given by you to your lawyers is privileged and confidential - your lawyers and their staff cannot be compelled to testify against you. Being represented by lawyers early on in the audit process can also encourage the tax authorities to treat you fairly to begin with, so as to avoid a protracted appeal to the Tax Court of Canada. However, many lawyers are not mathematically inclined and need to rely on accounting firms to organize the facts and data for them. The involvement of multiple firms can end-up costing you unnecessary legal and accountant fees. More importantly, there is always the risk of important information getting missed among the letters exchanged between a taxpayer's lawyer and accountant. To address these concerns, we have created professional teams staffed by lawyers and accountants for an integrated approach to serving taxpayers. While all our clients' communication to us remain solicitor-client privileged, our clients can benefit from the often superior number-crunching and fact-gathering skills of our in-house accountants, while also rely on the legal expertise of our lawyers to fight for their rights both at the negotiating tables and inside the courtrooms. Our tax law practice is headed up by Mr. Stephen Du, who is a both a courtroom lawyer and a seasoned chartered accountant.
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