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The Canadian tax system is extremely complex and our governments possess vast resources, both human and material, to audit the compliance of taxpayers.
Technological advancements have permitted the tax departments to develop more sophisticated audit methods, all augmenting the “coverage ratio” of audited businesses and verified taxpayers.
Other factors such as globalization and the development of taxes and duties of all sorts contribute to the presence of tax authorities in the lives of Canadian businesses and taxpayers.
Our tax litigation team responds to the needs of these businesses and taxpayers and assists at every step of the process, including:
- the protection of the rights of taxpayers during all audits by the tax authorities, dealing with corporate and personal income tax, GST and QST or any other taxes or duties;
- the exercise of all administrative recourses available;
- the representation of taxpayers before both civil and penal tax tribunals;
- the negotiation of settlements with the tax authorities;
- the presentation of voluntary disclosures for delinquent taxpayers who wish to regularize their situation with the tax authorities, for example, by repatriating sums held outside of Canada;
- the negotiation of terms of payment or recourses pursuant to the laws regarding bankruptcy and insolvency, and the handling of recourses available to the taxation authorities against third parties (liability of directors and officers, reviewable transfers, etc.) when the claims of the fiscal authorities exceed the capacity of the business or taxpayer to pay.
Our philosophy is to negotiate any situation in an amicable fashion and in the best interest of all parties involved. We do not, however, hesitate to represent our clients before the courts when it is unavoidable.
Our approach permits us to maintain a vast network of contacts with senior tax department officials founded upon trust and mutual respect which enables us to frequently avoid preliminary steps which may be long and costly and in turn allows us to reach the final stages of a file in a more efficient manner.
By eliminating inefficient debates, our clients can continue to focus their resources towards the realization of the objectives of their business.
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