Common questions about CRA disputes.
If you do not see your question here, contact us. We are happy to talk through the basics of your situation before you decide whether to retain counsel.
What does a tax lawyer do that an accountant does not?
An accountant prepares returns and advises on compliance. A tax lawyer represents you in disputes with the CRA, asserts legal privilege over your communications, drafts pleadings, appears in the Tax Court of Canada, and structures arguments that are heard as legal arguments rather than as accounting positions. The two roles complement each other but are distinct.
When should I hire a tax lawyer?
As early as possible once a dispute appears likely. The most expensive moment to hire counsel is after a problem has been allowed to develop unattended. Once an audit is underway, a Notice of Reassessment has issued, or a deadline is approaching, the calculus is usually clear.
How do CRA audits actually work?
An auditor reviews your filings, requests records, and tests positions taken on the return. The audit can be conducted by mail or in person and can cover one year or several. It usually ends with either a closing letter or a proposal letter setting out intended adjustments, followed by a reassessment if matters are not resolved.
What is a Notice of Objection?
A Notice of Objection is the formal written challenge to a CRA reassessment. It triggers review by the CRA Appeals Division, which is independent of the audit team. The deadline to file is generally 90 days from the date on the reassessment.
How long does the objection process take?
Most objections are resolved within nine to eighteen months. Complex or large-dollar files take longer. Files tied to CRA project initiatives, where many similar matters are queued, can also extend beyond that range.
What is the Voluntary Disclosure Program?
The VDP allows taxpayers to come forward and correct prior non-compliance. Where accepted, the application provides relief from penalties and from the risk of criminal prosecution, with partial interest relief available in many cases. The eligibility criteria are strict and the program rewards careful preparation.
When does a tax dispute go to Tax Court?
Once the CRA confirms a reassessment after objection, or if 90 days pass without a decision being issued on the objection, the taxpayer may appeal to the Tax Court of Canada. The deadline to file the Notice of Appeal is generally 90 days from the date of the confirmation.
How do fees work at Taxpayer Law?
We use scoped engagements. After reviewing the initial materials, we either quote a fixed fee for defined work or set out a clear hourly arrangement with an estimated range. You will know what to expect before substantive work begins, and we send detailed monthly statements.
Do you handle GST/HST disputes?
Yes. GST/HST audits, ITC denials, registration disputes, and Tax Court appeals under the Excise Tax Act are a regular part of the firm's work. Our lawyers are experienced with the specific procedural rules that apply to indirect tax matters.
How do I stop CRA collections action?
It depends on the underlying matter. For personal income tax under objection, collections is generally paused. For corporate tax and GST/HST, the rules differ and active intervention is often required. We work with the CRA Collections division to halt enforcement, address garnishments, and negotiate workable arrangements.
Do you represent clients outside Toronto?
Yes. We are based in Toronto and we represent clients across Canada. CRA work is largely conducted in writing and by telephone, and Tax Court of Canada hearings are held in cities across the country.
What is the first step?
Call us, send us an email, or use the contact form. We will arrange a confidential initial discussion to understand your situation, identify any time-critical issues, and tell you whether we can help. There is no obligation.
Your CRA file deserves serious counsel.
Whether you have just received an audit letter or you are weeks away from a Tax Court hearing, we can help. Initial consultations are confidential and we work with clients across Canada.