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Tax Disputes

A tax dispute with the CRA arises in circumstances where you disagree with the amount of tax that you have been assessed to pay in a Notice of Assessment or Notice of Reassessment.

What is a Notice of Assessment/Reassessment

A Notice of Assessment is a statement sent by the CRA to taxpayers which details the amount of income tax that they owe.

A Notice of Reassessment is a second statement sent by the CRA which changes the CRA’s initial Assessment and usually increases the amount of tax that is owed.

When is a Notice of Assessment/Reassessment Issued

A Notice of Assessment is issued to you each year after you have filed your personal or corporate Income Tax Return. A Notice of Assessment can deny certain expenses or credits that you have claimed, thereby increasing your taxable income and increasing the tax you must pay.

A Notice of Reassessment can be issued in a variety of circumstances. It can be issued after the completion of an Audit, which typically concludes that you owe more tax. The CRA may even issue Notices of Assessment or Reassessment without first auditing or even contacting you. These types of assessments include:

  • Notional / Arbitrary Assessments;
  • Third Party Assessments for Directors Liability; or
  • Third Party Assessments under Section 160 of the Income Tax Act.

What is an Objection

A Notice of Objection is a type of internal appeal that can be filed with the CRA to dispute the amount of tax levied in a Notice of Assessment or Reassessment.

Our lawyers prepare the initial Notice of Objection in which we object to the over-assessment of tax. We coordinate the objection process, gather the supporting documentation to further our objection, and prepare robust legal submissions to the appeals officer on your behalf. In doing so, we seek to eliminate the additional taxes levied by the CRA.

If you have been issued a Notice of Assessment or Notice of Reassessment and you do not agree with the taxes owed, contact us for assistance. With years of experience in corporate and tax law, we have the tools and knowledge to fight for your interests against the CRA.

Been over-assessed for tax? We’re here to help™.


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