Disagreements with the Canada Revenue Agency (CRA) can arise from audits, reassessments, or penalties. Whether it’s a personal tax issue or a business-related matter, CRA disputes can be stressful and complex. Without expert guidance, you may face significant financial and legal consequences.
COMMON REASONS FOR CRA DISPUTES
CRA disputes often stem from:
Reassessments or denied deductions;
- Penalties for unreported income;
- Disagreements over GST/HST or payroll taxes;
- Tax residency challenges;
- Offshore asset reporting (e.g., T1135 compliance); or
- Perceived inaccuracies in tax returns.
These disputes require prompt action and an effective strategy to resolve them.
YOUR RIGHTS IN A CRA DISPUTE
As a taxpayer, you have the right to:
- Challenge CRA decisions by filing a Notice of Objection;
- Access all relevant documentation used in the CRA’s assessment;
- Be treated fairly and professionally; and
- Appeal to the Tax Court of Canada if necessary.
Understanding these rights is critical to protecting yourself against unjust assessments or penalties.
HOW A TAX LAWYER CAN HELP WITH CRA DISPUTES
A skilled CRA dispute resolution lawyer can:
- Evaluate Your Case
We’ll review your case in detail, assess the CRA’s claims, and identify potential errors or oversights in their assessment. - File a Notice of Objection
If you disagree with the CRA’s decision, we’ll file a formal objection on your behalf and present a compelling case to the Appeals Division. - Negotiate with the CRA
With years of experience dealing with CRA auditors and lawyers, we know how to negotiate effectively to reduce penalties and reassessments. - Prepare for Tax Court or Federal Court
If the CRA denies your objection, we can represent you before the Tax Court of Canada or escalate the matter to the Federal Court of Appeal if necessary. - Protect Your Interests
Beyond resolving disputes, we’ll work to prevent future CRA issues by ensuring your tax filings are compliant and accurately reflect your situation.
WHY CHOOSE SPENCEDRAKE TAX LAW?
At SpenceDrake Tax Law, we specialize in resolving disputes with the CRA. Our expertise includes:
- Handling complex objections and appeals
- Navigating tax residency and cross-border disputes
- Resolving corporate and personal tax reassessments
- Defending clients in Tax Court and beyond
With extensive experience in tax litigation and a deep understanding of Canadian tax law, we’ve successfully defended hundreds of clients against CRA claims.
DEADLINES
CRA disputes have strict deadlines. Missing a deadline to file an objection or appeal can severely limit your options.
Contact us today for a consultation, and let us help you navigate the CRA dispute resolution process with confidence.
Jeff Kirshen, BA, JD(US), JD(CDN)
Partner & Tax Lawyer
Disclaimer
Each article/blog post is only meant to provide general information. It is posted on a specific date. Laws and rules change. Please know that it may be out of date. It is not meant to provide legal advice, and it does not provide legal advice. It cannot be relied on. Every tax situation is unique, and that may mean situations differ from this article/blog. If you have legal questions, please consult a lawyer.