In tax disputes, the burden of proof is on the taxpayer. This means, that it’s you that must prove that your position is correct. The CRA does not have to prove that their reassessment is correct. This entitles CRA employees to make assumptions and, in some instances, emboldens them to behave unreasonably. The best antidote [...]

Reaching a settlement agreement with the CRA is often the most efficient and affordable means of resolving a tax dispute. And indeed, our experience is that about 95% of tax disputes settle before going to trial. But negotiating a settlement in a tax dispute is very different from negotiating a settlement in normal litigation or [...]

If you’ve clicked on this question, the answer is probably “now”. There’s no downside to making the call. Plus, one of the keys to succeeding in a tax dispute is developing, at the outset, a winning-argument and then sticking to that argument throughout the entirety of the dispute. Often, the most damning evidence we have [...]

Canadian tax law imposes strict time deadlines on taxpayers who wish to dispute a Notice of Reassessment by the CRA. If you miss one of these deadlines, you lose all rights to dispute the reassessment, which may leave you with no choice but to pay the full amount. The day on which the CRA issues [...]

A typical tax dispute begins with the CRA conducting an audit. If the CRA does not agree with the amount of tax that you initially reported owing, they will issue you a Notice of Reassessment. Once the CRA has issued the Notice of Reassessment (and before the time deadline), you can file a Notice of [...]

There is hope. In 2016 the Auditor General released a report in which it found that 65% of taxpayers are fully or partially successful in objecting to a Notice of Reassessment. This does not include the taxpayers who go on to succeed after filing an appeal to the Tax Court of Canada. We often obtain [...]

A Notice of Reassessment (“NoR”) is very different from a Notice of Assessment (“NoA”). When you file your tax return, the CRA will process your return and issue you a NoA, usually within two to eight weeks. The NoA typically confirms the amount of tax that you owe based on what you reported in your [...]