If you haven’t filed your tax returns in years, failed to report income, or claimed questionable expenses, you’re not alone—and the sooner you address the issue, the more options you have. Our firm regularly helps clients in exactly this position take control of their tax situation and move forward with confidence. We understand how stressful and overwhelming it can be to face years of non-compliance, especially when you’re unsure where to start or worried about penalties, audits, or prosecution. That’s where we come in. Once retained, we become your authorized representative with the CRA, taking over all communications on your behalf. We will work with you to understand your specific circumstances, gather the necessary information, and get your returns filed properly and strategically. Whether through voluntary disclosure, amended filings, or a structured compliance plan, we will guide you every step of the way and advocate for the most favourable outcome possible. If the CRA has already contacted you—or if you fear they might—we can intervene to protect your interests, respond to inquiries, and manage the process so that you’re not navigating it alone. Our goal is to take the weight off your shoulders, minimize exposure to penalties and interest, and help you get back into full compliance with minimal disruption. Don’t wait for the CRA to come knocking—reach out to us and let our experienced team handle the process for you, professionally and discreetly.
A net worth audit is one of the most aggressive and intrusive audit techniques employed by the Canada Revenue Agency (CRA), used when the CRA believes a taxpayer’s reported income does not align with their observed accumulation of assets, spending patterns, or financial activity. Rather than relying on traditional books and records, the CRA reconstructs a taxpayer’s income over a multi-year period by calculating the increase in their net worth—assets minus liabilities—adjusted for personal expenditures. This method is typically applied where the CRA alleges that a taxpayer’s financial statements are unreliable, or where lifestyle and asset growth appear inconsistent with declared income. Crucially, a net worth audit is a presumptive assessment: the CRA assumes that any increase in wealth is derived from unreported, taxable income unless the taxpayer can prove otherwise. The burden of proof falls squarely on the taxpayer to explain the source of funds, whether from gifts, loans, inheritances, or non-taxable sources. Where the CRA concludes (often incorrectly) that income has been deliberately concealed, it may impose gross negligence penalties under section 163(2) of the Income Tax Act—equal to 50% of the tax avoided—and in more serious cases, refer the file for criminal investigation and prosecution. Our team of experienced tax lawyers and forensic accountants has extensive experience defending against net worth assessments. We conduct a line-by-line review of the CRA’s analysis, identify flawed assumptions and missing context, and assemble the necessary documentary evidence to explain legitimate increases in net worth. We also challenge procedural irregularities and improper valuation methods that inflate the assessment. If you are facing a net worth audit, the stakes are high—but with the right representation, they are also manageable. We can help you protect your legal and financial position with a rigorous, strategic defence.
The Voluntary Disclosures Program (VDP) is a valuable opportunity for taxpayers to correct past errors or omissions in their tax filings before the Canada Revenue Agency (CRA) becomes aware of them—whether through audits, third-party reporting, data matching, or whistleblower tips. The VDP is an administrative program that offers significant benefits, including potential relief from late-filing penalties, partial interest relief, and protection from criminal prosecution. It can apply to a wide range of issues, from unfiled returns and unreported income to improper expense claims or foreign asset non-disclosure. Whether the error was inadvertent or intentional, early legal advice is essential to managing risk and protecting your rights. Our team of experienced tax lawyers provides a privileged and confidential review of your situation, including a detailed legal analysis of your potential tax exposure and a risk assessment of detection by the CRA. If you decide to proceed, we handle the entire disclosure process from start to finish: preparing all required tax filings, assembling a thorough legal submission, and engaging with the CRA on your behalf. If your disclosure is accepted, we can also assist in negotiating a reasonable resolution of your outstanding tax balances. If you ultimately decide not to move forward, any information you provide to us—including your identity—remains fully protected by solicitor-client privilege, unlike with accountants or other non-legal advisors. If you’re concerned about past non-compliance, now is the time to take control. We can help you correct the past—confidentially, strategically, and with the least possible exposure.
Our firm is highly experienced in defending against section 160 assessments, one of the most unforgiving and misunderstood provisions in the Income Tax Act. These assessments allow the CRA to pursue family members, business associates, or other transferees for the tax debts of another person — often years after the original debt arose. What makes section 160 particularly harsh is that it applies regardless of intent and without any requirement that the transferee had knowledge of the underlying tax liability. Successfully defending against these claims requires more than just legal skill — it demands a precise understanding of the statutory framework, the jurisprudence interpreting “fair market value” and “consideration,” and the evidentiary thresholds the CRA must meet. Our lawyers are deeply versed in the technical nuances of section 160, including exceptions, timing issues, and valuation disputes. We work closely with clients to reconstruct transactions, establish defences, and challenge the CRA’s assumptions head-on. Whether you’re a spouse, child, or business partner being drawn into a tax dispute you never expected, we will do everything possible to protect your interests, assert your strongest available defences, and put your best foot forward—both during the audit stage and in litigation before the Tax Court of Canada.
Our firm has extensive experience defending directors facing personal liability assessments for unremitted employee source deductions and GST/HST, one of the most aggressive enforcement tools available to the Canada Revenue Agency. These assessments can be devastating—imposing personal financial exposure even where the underlying business has failed. What sets us apart is our deep technical knowledge of the statutory defences available under the Income Tax Act and Excise Tax Act, including due diligence, procedural compliance, and timing-based arguments. We understand how these assessments are built—and more importantly, how they can be dismantled. Unlike general practitioners or corporate counsel unfamiliar with the nuances of tax enforcement, our lawyers focus exclusively on tax disputes and know how to craft compelling legal and evidentiary strategies that give our clients the strongest possible footing. From challenging the CRA’s conduct during the assessment process to assembling the documentation and witness testimony necessary to support a due diligence defence, we leave no stone unturned in advancing your case. If you’re a director facing a personal assessment, we will fight to protect your rights, mitigate your exposure, and put you in the best position for a successful resolution.
When a taxpayer disagrees with a tax assessment or reassessment issued by the Canada Revenue Agency (CRA), filing a Notice of Objection is the critical first step in challenging that assessment. The objection process is not only a statutory prerequisite to filing an appeal with the Tax Court of Canada, but also a valuable opportunity to resolve the dispute without resorting to litigation. Timelines are strict: a Notice of Objection must ordinarily be filed within 90 days from the date of the assessment or reassessment. In certain circumstances, an extension of up to one additional year may be granted, but only if specific legislative criteria are met and the extension application is properly submitted within one year plus 90 days of the assessment date. If this deadline is missed, the right to dispute the assessment may be permanently lost, regardless of the underlying merits of the case. Filing a timely objection is therefore essential not only to preserve your appeal rights, but also to engage the CRA’s Appeals Division, which conducts a fresh, independent review of the matter—separate from the original auditor or assessing officer. The Appeals Officer has the authority to confirm, vary, or vacate the assessment and will consider legal submissions, new factual clarifications, and supporting documentation. Importantly, filing an objection also triggers a stay of collection enforcement for most income tax debts (excluding source deductions and GST/HST), offering financial breathing room while the dispute is under review. Our experienced tax lawyers routinely prepare detailed, strategic objections that put our clients in the strongest possible position—whether the goal is resolution at the administrative level or setting the stage for a successful appeal before the Tax Court. If you have received an assessment you believe is incorrect, it is critical to act quickly and strategically to protect your rights.
If a taxpayer disagrees with the CRA’s decision following an objection—whether because the Appeals Officer has confirmed the assessment or issued a reassessment that remains in dispute—the next step is to appeal to the Tax Court of Canada. This must be done by filing a Notice of Appeal within 90 days of receiving the CRA’s decision or reassessment. At the outset, the taxpayer must choose between two procedural tracks: the Informal Procedure, intended for smaller disputes (generally under $25,000 per taxation year or $50,000 for GST/HST), and the General Procedure, which applies to more complex or higher-value matters and involves formal rules of procedure and evidence. Under the General Procedure, the parties first exchange pleadings—the taxpayer files a Notice of Appeal, and the CRA, represented by the Department of Justice, files a Reply outlining their legal and factual positions. This is followed by discovery, where the parties exchange documents and conduct oral examinations under oath to explore the issues in dispute.
Throughout this process, our firm works strategically to position our clients for success, whether by advancing compelling legal arguments, identifying evidentiary weaknesses in the CRA’s position, or negotiating a favourable resolution. In most cases, these disputes are resolved through settlement discussions with Department of Justice counsel prior to trial. If the matter proceeds to a hearing, the case is presented before a Tax Court judge, with witnesses, evidence, and legal submissions. The judge may issue a decision orally or reserve judgment and release detailed written reasons. If the taxpayer is unsuccessful, the decision may be further appealed to the Federal Court of Appeal.
It is important to note that interest continues to accrue on disputed tax debts during this process, and the Court may also award costs, making strategic assessment and careful case management essential. Our experienced tax litigation lawyers have a strong track record of success before the Tax Court of Canada. We combine deep knowledge of substantive tax law with practical litigation skills to deliver effective, efficient, and outcome-driven representation. Whether the case involves income tax reassessments, GST/HST disputes, or complex procedural and evidentiary issues, we are committed to protecting our clients’ interests and budget by working to achieve the best possible result at the lowest possible cost.
At our firm, we specialize in defending clients facing criminal tax evasion charges, offering a unique advantage that sets us apart from conventional criminal defence lawyers: an in-depth and practical understanding of Canada’s complex tax and regulatory framework. Our lawyers are not only experienced in criminal litigation, but also deeply versed in the Income Tax Act, the Excise Tax Act, and the procedural intricacies of CRA audits, assessments, and investigations. We understand how civil and criminal tax processes intersect, and we know how to leverage that knowledge to our clients’ benefit—whether by identifying procedural overreach during an audit, challenging the validity of search warrants, or dissecting the evidentiary basis of a prosecution. This dual perspective allows us to anticipate how the CRA builds its case and to strategically respond with both legal and technical arguments that protect our clients’ interests at every stage. From pre-charge negotiations and voluntary disclosures to full trial defence, we offer comprehensive and proactive representation aimed at achieving the best possible outcome while minimizing financial and reputational exposure.
An audit by the Canada Revenue Agency (CRA) is a formal and often intensive review of a taxpayer’s books, records, and tax filings to verify compliance with Canadian tax laws—most commonly the Income Tax Act (for income tax and payroll) or the Excise Tax Act (for GST/HST). While some audits are relatively limited in scope—such as desk audits conducted through written correspondence—others are far more intrusive, including field audits, where CRA auditors conduct in-person site visits, review physical and electronic business records, and interview employees or directors. The CRA also conducts targeted specialty audits, such as Trust Account Examinations focused on payroll and GST/HST compliance. These audits are treated with particular seriousness, as they involve deemed trust funds—amounts withheld from employees (such as income tax, CPP, and EI) or collected from customers as GST/HST. From the CRA’s perspective, these are not your funds—they are monies held in trust for the federal government—and failure to remit them properly or on time often triggers aggressive enforcement action. In many cases, directors of corporations can be personally assessed for unpaid amounts, even years after the fact. Our firm has significant experience defending clients through the audit process, from the initial CRA contact letter through to post-audit negotiations, objection, or litigation. We assist in organizing and presenting your records, managing all communications with auditors, identifying and correcting errors before they escalate, and challenging unreasonable positions or assessments. Whether the audit involves unreported income, improperly claimed expenses, payroll issues, or GST/HST liabilities, our tax lawyers offer strategic, experienced guidance to protect your rights and minimize your exposure. If you are facing a CRA audit—or expect one—early legal representation can make all the difference in the outcome.
Our firm offers privileged and confidential tax reviews designed to give individuals and businesses the clarity they need—without exposing themselves to the Canada Revenue Agency. Whether you are contemplating a complex transaction, concerned about past filings, or responding to a CRA inquiry, engaging a tax lawyer ensures that your communications and legal analysis are protected by solicitor-client privilege—something accountants and other non-lawyers cannot provide. This privilege can be critical in preventing sensitive information from being disclosed to the CRA or used against you in an audit or reassessment. Our lawyers are not only experienced litigators, but also skilled tax advisors with deep expertise in corporate structuring, reorganizations, income splitting, GST/HST issues, and cross-border tax matters. We work proactively with clients to review, restructure, or support proposed transactions with defensible legal positions, ensuring that risks are identified early and managed strategically. Whether acting independently or in collaboration with your existing accountant, we provide discreet and legally protected advice that puts you in control of your tax affairs while minimizing exposure. When the stakes are high, and confidentiality matters, our firm delivers the insight and protection that only experienced tax counsel can provide.
Our firm provides strategic, confidential legal advice to individuals and businesses navigating the complex and high-stakes world of offshore tax compliance. Whether you hold foreign assets, operate cross-border businesses, or inherited an estate with unreported offshore income or accounts, our lawyers have the expertise to guide you through every stage of compliance and risk management. With increased international information sharing and aggressive enforcement by the CRA using tax information exchange agreements, offshore tax issues can quickly escalate into significant financial and legal exposure. What sets us apart is not only our deep understanding of Canada’s foreign reporting requirements—such as Form T1135, foreign affiliate rules, and offshore trust reporting—but also our ability to deliver legal advice that is fully protected by solicitor-client privilege. Unlike accountants or consultants, communications with our firm are confidential and cannot be compelled by the CRA, providing a critical layer of protection when dealing with sensitive issues. Whether you are considering a voluntary disclosure, responding to an audit, or proactively reviewing your offshore affairs, we offer discreet, strategic advice tailored to your circumstances and focused on achieving full compliance while minimizing risk. When it comes to offshore tax matters, experience, precision, and confidentiality are essential—and that’s exactly what we provide.
Our firm has helped many individuals and business owners resolve overwhelming tax debt by working directly with licensed insolvency trustees, the Canada Revenue Agency (CRA), and other creditors to find practical, lasting solutions. If you have unfiled tax returns or outstanding balances that you can’t reasonably repay, you’re not alone—and you’re not without options. We routinely assist clients in getting back into compliance by filing overdue returns and then negotiating the resolution of their tax debts through consumer or Division I proposals under the Bankruptcy and Insolvency Act. These proposals are a powerful legal tool: they stop CRA collections, freeze interest from accruing, and allow debts to be consolidated and repaid over a manageable term—typically three to five years of consistent monthly payments. Unlike informal payment arrangements, a creditor proposal is one of the only legal mechanisms that can force the CRA to accept less than the full amount assessed. Our team understands how the CRA assesses and collects tax debt, and we work with trustees and taxpayers to craft proposals that are fair, affordable, and realistic. Many clients come to us after years of struggling to make payments they simply cannot afford—often under pressure from garnishments, liens, and escalating interest. If you’re burdened by tax debt and unsure where to turn, contact us to assess your options. We can help you put an end to the stress and start down a path toward financial stability, with a resolution that actually works.
Cross-border moves—whether relocating to Canada or departing for another jurisdiction—carry significant and often overlooked Canadian tax implications. Canada’s tax system is based on residency, and a change in tax residence can trigger a range of complex consequences, including deemed dispositions of assets, the need for inbound or outbound tax planning, and compliance with detailed foreign reporting obligations. Individuals moving to Canada become subject to Canadian tax on their worldwide income, and must navigate rules regarding foreign property disclosures (Form T1135), cost base adjustments, and the potential impact of foreign tax credits and treaty relief. Conversely, individuals leaving Canada may face a departure tax, which treats certain assets as if they were sold immediately prior to emigration—potentially triggering significant capital gains and future compliance obligations. Whether you are a high-net-worth individual, a business owner, or an executive with global assets, the stakes are high and the rules are nuanced.
Our tax lawyers are experienced in advising on residency determinations, treaty tie-breaker rules, departure tax planning, and the effective use of foreign tax treaties to minimize double taxation and avoid costly reporting errors. We provide tailored, strategic guidance to help clients structure their affairs before, during, and after a cross-border move—ensuring compliance, preserving wealth, and avoiding unpleasant surprises. Whether you are arriving in Canada, planning an exit, or navigating dual residency concerns, we offer precise legal advice backed by solicitor-client privilege and a deep understanding of both Canadian domestic tax law and international tax conventions. Let us help you manage your global transition with confidence and clarity.
When the Canada Revenue Agency (CRA) makes a decision that is procedurally unfair, unreasonable, or outside the scope of its lawful authority, taxpayers may have the right to challenge that decision through an application for judicial review in the Federal Court. Judicial review is the appropriate legal remedy where no statutory right of appeal exists—such as in disputes over voluntary disclosure rejections, taxpayer relief (fairness) denials, collection actions, or decisions made under the CRA’s discretionary powers. Unlike appeals to the Tax Court, which review the correctness of an assessment, judicial review focuses on the legality and fairness of the CRA’s decision-making process. The Court examines whether the CRA followed proper procedures, respected principles of natural justice, and reached a decision that was reasonable in light of the evidence and applicable legal framework.
Our firm has experience representing individuals, businesses, and charities in judicial review applications, and we understand the strategic considerations necessary to build a compelling case within tight timelines—typically 30 days from the date the CRA’s decision is communicated. We prepare detailed legal arguments, obtain the full administrative record from the CRA, and rigorously challenge flawed reasoning, misapplication of policy, or procedural unfairness. Judicial review is a highly technical and specialized area of administrative law, and success depends on a precise understanding of the standard of review, the CRA’s delegated authority, and the Federal Court’s procedural rules. Our lawyers are uniquely positioned to assist clients in navigating this process, holding the CRA accountable, and achieving fair treatment under the law. If you’ve received an adverse discretionary decision from the CRA, contact us to evaluate whether judicial review is the right path forward.
When tax outcomes arise that are fundamentally inconsistent with what the parties intended—whether due to drafting errors, misunderstood legal effects, or unforeseen tax consequences—Canadian law provides several exceptional remedies: rectification, rescission, and remission orders. These are not routine tools—they are complex, high-stakes legal remedies that require skilled advocacy and a precise understanding of both tax and equity jurisprudence.
A rectification application, brought in the superior court of the relevant province, allows taxpayers to correct written instruments—such as corporate resolutions, agreements, or reorganizational steps—so that they reflect the parties’ original and continuing intention. It is not a vehicle for retroactive tax planning, but rather a narrowly applied remedy where documentary errors have led to unintended and adverse tax consequences. In contrast, rescission—a remedy rooted in equity—may be available in rare circumstances where the entire transaction must be unwound because it was entered into under a fundamental mistake, often involving a complete failure to appreciate its legal effect. Canadian courts are increasingly cautious in granting rectification and rescission, but these remedies remain viable where injustice would otherwise result. Finally, remission orders, authorized under section 23 of the Financial Administration Act, allow taxpayers to seek discretionary relief from taxes, penalties, or interest where collection would result in undue hardship, inequity, or where government error has played a role. These applications are made to the CRA and reviewed by the Minister of National Revenue, with ultimate approval granted by the Governor in Council.
Our firm has experience guiding clients through each of these extraordinary remedies. We work closely with accountants, planners, and legal counsel to gather the evidence necessary to demonstrate original intent, legal misunderstanding, or the circumstances justifying equitable relief. We prepare comprehensive, persuasive court submissions for rectification and rescission, detailing compelling narratives backed by legal authority and sound policy rationale. These are not remedies for the unprepared. They require strategic insight, technical precision, and a command of both tax law and equity.
Whether you are correcting a transactional misstep, seeking to unwind an unintended legal result, or pursuing relief from an unfair tax liability, our experienced tax lawyers will help you assess your options and pursue the strongest possible path forward—discreetly, professionally, and with a relentless focus on achieving a just result.
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Email: info@taxninja.ca
Phone: 403-855-4031
Fax: 1-888-876-9243
Email: info@taxninja.ca
Phone: 416-572-9579
Fax: 1-888-876-9243
Email: info@taxninja.ca
Phone: 236-259-1715
Fax: 1-888-876-9243
Email: info@taxninja.ca
