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Tax Dispute Resolution

Managing interactions with tax authorities

The federal government has made significant investments in the Canada Revenue Agency (CRA), resulting in a substantial increase in the number and size of tax audits and assessments. Canadian businesses and high-net-worth individuals also face relatively ambiguous tax rules and a challenging and time-sensitive dispute resolution process.

It’s important to strategically manage your interactions with tax authorities in a way that adds value by avoiding disputes and effectively resolving disputed issues with full knowledge of the rules, internal government processes and various methods of resolution.

Woman talking with colleague

Our approach to the tax dispute life cycle

Our strategy is to proactively prevent, efficiently manage and favourable resolve your tax disputes and audits throughout the world.

Our specialized team brings together former tax authority personnel, former federal finance and justice department employees, tax litigation lawyers and other tax, accounting and process experts as needed, supplemented by insights from our global network. The goal is to strategically manage all aspects of your interactions with tax authorities in the following three phases of the tax dispute life cycle.

Prevent Manage Resolve Save Money

* Save money by strategically interacting with Tax Authorities

Prevent: Are you "audit ready"?

  • Examine and document pre-audit risks
  • Consider whether legal or litigation privilege is warranted

Manage: How do you prepare for an audit?

  • Have a strategy (get their audit plan, know your rights and stay on top of things)
  • Be aware of internal CRA policies

Resolve: What are the possible paths for resolution?

  • Settlement, Objections/Appeals
  • Litigation

How we help

We’re seeing an increase in the number and size of tax audits, assessments and disputes with revenue authorities worldwide. Organizations need to develop coordinated approaches to audits and disputes, adopt preventative measures and use traditional and alternative dispute resolution techniques to better manage their tax audits and document their filing positions up front.

We can help you:

  • gain a better understanding of your company’s risks and exposures
  • develop sound policies and processes to help safeguard your organization against audits and disputes
  • implement consistent and defensible practices and policies
  • manage your tax disputes, audits and examinations worldwide

Prevent

  1. Build defence strategies into the structure and operations of the enterprise.
  2. File and negotiate advance tax rulings, advance pricing agreements and mutual agreement procedures.
  3. Assist in transactional due diligence to identify tax audit risks and exposures.
  4. Examine a company’s risk profile and develop an audit-readiness tax file.
  5. Maximize the scope of privilege where appropriate.

Audit Management

  1. Use our knowledge of internal government processes and the scope of taxpayer rights to minimize the time, effort and expense associated with audits.
  2. Make sure the CRA follows their clearly defined audit processes. 
  3. Examine the possibility of settling matters at the audit stage.
  4. Strategize when to escalate matters within the proper channels within the tax authority.

Resolve

  1. Use a variety of litigation and other processes to reach a favourable resolution without a trial—and be ready for a trial if needed.
  2. Strategize whether bypassing CRA Appeals toward the Tax Court is advisable.
  3. Know when to enter into negotiated settlements with CRA Appeals or the Department of Justice prior to trial.

Contact us

Ted Cook

Ted Cook

Partner, Tax Dispute Resolution Services, PwC Law LLP, Canada

Tel: +1 613 755 4360

Timothy Fitzsimmons

Timothy Fitzsimmons

Partner, PwC Law LLP

Tel: +1 416 687 8584

Patrick  Lindsay

Patrick Lindsay

Partner, PwC Law LLP

Tel: +1 403 509 6386

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