– Practice Area
Tax Advisory and Structuring
Tax Planning and Advisory is a proactive service that helps individuals and businesses legally reduce their tax burden by planning ahead instead of reacting at year-end. It involves reviewing income, expenses, investments, business structure, and future goals to identify strategies that minimize taxes, improve cash flow, and avoid costly surprises.
Unlike basic tax filing, tax planning focuses on long-term strategy. It may include timing income and expenses, maximizing deductions and credits, structuring compensation efficiently, planning for major transactions, and preparing for growth or succession. The goal is to ensure compliance with tax laws while optimizing overall financial performance throughout the year — not just during tax season.
We can review your existing corporate structure and provide advice about alternative arrangements that could reduce your risks or improve your tax efficiency. In addition to planning corporate reorganizations, we can also implement transactions which have been proposed by tax accountants or other advisors. If you are uncertain about the tax treatment of a past transaction, we can provide clarity through issuing a legal opinion or working directly with your existing advisors to reach clarity.
We provide continuous support throughout the implementation of the advised strategies, ensuring a seamless execution of the proposed tax structuring while keeping you informed of progress. Throughout the process, we communicate with you and your advisors to ensure you understand what we are doing and why.
Audit Representation
We believe an ounce of prevention is worth a pound of cure. Most taxpayers will be involved in only one high stakes audit in their lifetime—we represent clients in dozens of audits every year. That experience counts. We can ensure that your responses to the CRA are effective in protecting your interests. By acting as your intermediary, we can also minimize disruption to your business.
We help our clients respond not only to formal business audits, but also to CRA inquiries related to TFSAs, RRSPs, director liability, third party liability (non-arm’s length transfers), property sales, and more. When you partner with us, we will begin by conducting a thorough review of all relevant documentation and correspondence in order to develop a strategy. We will work with you to ensure that any communication with the CRA is effective in protecting your interests. By acting as your intermediary, we can also minimize disruption to your business. If the CRA proposes adjustments to your tax returns, we will explain the reasons for those adjustments and respond on your behalf. If the CRA makes a final decision that you disagree with, our work on the audit can be carried forward with a notice of objection or an appeal to Tax Court. We ensure you are well-informed at every step of the audit process and provide regular updates along the way.
Tax Assessments
Once an audit is completed, the CRA or Revenu Quebec may issue a Notice of Assessment. From the moment it is issued, the assessed amount becomes a tax debt, even if you disagree with it.
You have 90 days to file a formal objection. The objection will be reviewed by a different CRA officer in the Appeals Division. Missing this deadline can severely limit your ability to challenge the assessment.
You should obtain legal advice if:
- you face a significant tax liability;
- the CRA or Revenu Quebec have assessed you beyond the normal reassessment period;
- penalties have been imposed; or
- the assessment raises complex legal or factual issues.
We provide clear, strategic assessments of your legal position and guide you through objections and appeals with a focus on results.
Tax Litigation
Tax litigation is complex, technical, and high-stakes. Success requires more than a deep understanding of tax law—it demands a lawyer who knows how to navigate the court process, build persuasive arguments, and anticipate how judges approach tax disputes.
When a Tax Dispute Goes to Court
If your matter proceeds to litigation, it means your position was not accepted by the CRA or Revenu Quebec. The critical questions then become:
- Why was your position rejected?
- Is the tax authority’s position reasonable and supported by the law?
- What are the true legal and factual issues in dispute?
- How will a court likely assess the evidence and the applicable legislation?
- Do you have a strong, defensible case—and at what cost?
These questions must be answered clearly and objectively before taking the next step.
Experience That Makes the Difference
Effective tax litigation requires a unique skill set developed through years of hands-on experience. Every case must be analyzed within the framework of the legislation and the evolving jurisprudence, with careful attention to evidentiary strategy and procedural rules.
We assist clients in evaluating the strength of their case, identifying risks and opportunities, and developing a litigation strategy aligned with their objectives.
Clear Advice. Strategic Options. Flexible Fees.
We offer candid assessments of your position and guide you through the options available—whether that involves litigation, settlement discussions, or alternative resolutions. Flexible fee arrangements are available to suit your circumstances.