Tax Services

Tax Planning

Looking to minimize your tax burden and maximize savings? Our tax lawyers specialize in strategic tax planning to help you navigate the complexities of tax laws efficiently.

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Tax Planning

Effective tax planning is crucial for both individuals and businesses to optimize their financial strategy and comply with complex tax laws. At KR Law Firm, we specialize in offering comprehensive tax planning services designed to minimize tax liabilities and maximize financial efficiency.

Our tax planning services include:

Personal Tax Planning: We assist individuals in managing their personal tax affairs, ensuring they take advantage of all available tax-saving opportunities. This includes advice on income splitting, investment strategies, and retirement planning.
Business Tax Planning: For businesses, we provide strategic planning to reduce tax burdens while maintaining compliance with Canadian tax laws. Our services include corporate structure optimization, planning for business transactions, and identifying tax credits and deductions.
Estate and Succession Planning: We help clients in planning their estate and succession matters, ensuring tax-efficient transfer of assets to the next generation.
Compliance and Risk Management: Our team ensures that your tax planning strategies are compliant with current tax laws and regulations, thereby reducing the risk of disputes with the Canada Revenue Agency.

At KR Law Firm, we understand that tax laws are constantly evolving. Our dedicated professionals stay abreast of the latest tax legislation and judicial rulings, ensuring that our clients receive up-to-date and proactive tax advice. Whether you are an individual, a small business, or a multinational corporation, our tailored tax planning services are designed to meet your unique needs and financial goals.

Tax Audits

Being audited by the Canada Revenue Agency (CRA) can be a daunting and stressful experience for any business owner. However, with the right preparation and understanding of the audit process, it is possible to navigate the process smoothly and avoid potential legal issues.

The CRA is generally permitted to reassess tax returns for individuals and Canadian-controlled private corporations three years from the Notice of Assessment date. For large corporations, this timeframe can extend to four years. For GST/HST, the CRA can audit those returns for up to four years from the specific tax year. However, in cases where the CRA suspects fraud or negligence, there is no audit time limit, and the CRA will be able to audit as far back as it wants.

At KR Law Firm, we understand that the process of a CRA audit can be overwhelming and stressful for individuals and businesses. That’s why we are dedicated to providing expert legal guidance and representation to help you navigate the audit process and protect your rights and interests.

When you retain our services, we will work closely with you to understand your situation and to gather all of the necessary documentation and records. We will then review your financial records and help you prepare for the audit, including reviewing any potential areas of concern and identifying any potential exposure to taxes and penalties.

During the audit, we will be by your side every step of the way, representing your interests and communicating with the CRA on your behalf. Once the audit is completed, we will help you understand your options, including any potential appeals or objections. We will also help you to negotiate with the CRA, to minimize any potential penalties or fines, and to reach a fair and reasonable resolution.

If you or your business is facing a CRA audit, don’t hesitate to contact us. Our lawyers are here to help you protect your rights and interests and ensure the audit process is handled as smoothly and efficiently as possible.

Tax Audits

Received a notice of audit from the Canada Revenue Agency? Our tax lawyers can provide knowledgeable assistance throughout the audit process to ensure compliance and protect your rights.

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Real Estate Taxation

Concerned about the tax implications of your real estate investments? Our team provides expert guidance on real estate taxation to ensure your investments are both compliant and optimized for tax efficiency.

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Real Estate Taxation

Navigating the complexities of real estate taxation requires expert guidance to ensure compliance and optimize tax benefits. At KR Law Firm, we provide comprehensive real estate tax services for a diverse range of clients, including property owners, real estate developers, investors, and businesses.

Our real estate taxation services encompass:

Property Tax Assessments and Appeals: We assist clients in challenging property tax assessments, ensuring they pay only their fair share. Our team is skilled in negotiating with tax authorities and representing clients with their case.
Transaction Structuring: We advise on the tax implications of real estate transactions, including purchases, sales, and transfers. This includes structuring deals in a tax-efficient manner, considering factors such as capital gains, land transfer taxes, and GST/HST implications.
Real Estate Development Tax Planning: For real estate developers, we offer strategic tax planning advice to maximize profitability. This includes guidance on project structuring, financing, and leveraging tax credits and incentives.
Taxation of Real Estate Investments: We provide advice on the tax treatment of various real estate investment vehicles, including REITs (Real Estate Investment Trusts) and limited partnerships. Our focus is to optimize the tax position of our clients’ investments.
Estate Planning and Real Estate: We offer estate planning services that consider the tax implications of real estate holdings, ensuring efficient transfer and minimizing tax liabilities for estates and beneficiaries..

At KR Law Firm, we understand that real estate taxation is not just about compliance – it’s also about strategic planning and maximizing value. Whether you are dealing with a single property or a complex real estate portfolio, our team combines legal expertise with practical experience to provide tailored solutions.

Tax Residency

Canada imposes tax liability on the worldwide income of an individual, corporation or trusts on the basis of their tax residency status. As such, your tax residency status can have significant implications on your Canadian tax obligations, including the amount of taxes you owe and the types of income that are subject to Canadian tax.

Determining your tax residency status can be complex, as it involves looking at a variety of factors, including the length of time you have spent in Canada, the types of ties you have to Canada (such as property, family, and social ties), and your immigration status. The Canada Revenue Agency (CRA) may also consider other factors, such as the location of your assets and the jurisdiction of your professional and financial advisors. The CRA will also look at tax treaties Canada has entered into with certain other countries. If a taxpayer is determined to be a resident of two countries, the relevant tax treaty between the two countries will allocate the jurisdiction to tax the taxpayer to one of the two countries.

If you are uncertain about your tax residency status, our lawyers can advise you on your specific situation. We can help you navigate the complexities of Canadian tax residency and ensure that you are in compliance with Canadian tax laws. We can help you understand your Canadian tax obligations and assist you in minimizing your Canadian tax liability.

Tax Residency

Unsure about your tax residency status in Canada? Our tax lawyers can provide clarity and guidance on tax residency matters.

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Voluntary Disclosure Program

Worried about undisclosed tax liabilities? Explore the Voluntary Disclosure Program with our tax lawyers to rectify your tax situation and achieve compliance peace of mind.

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Voluntary Disclosure Program

The Voluntary Disclosures Program (VDP) is a program administered by the Canada Revenue Agency (CRA) that allows Canadian taxpayers to voluntarily come forward and declare previously undeclared income, correct past filed tax returns or give them information they may have left out in the past without the fear of penalty or prosecution.

Taxpayers can only use the VDP in specific situations, such as:

Failing to report taxable income

Not reporting GST/HST

Not disclosing excise taxes

Claiming ineligible or overstated expenses

Not remitting employees’ source deductions

Not filing information returns

Not reporting foreign-sourced income

Taxpayers cannot use the VDP in matters involving rollover provisions, elections, advance pricing arrangements, bankruptcy tax returns or post-assessment requests. Furthermore, the VDP only applies to a taxpayer’s last ten years of tax matters.

The CRA has divided the VDP into two: the VDP General Program and the VDP Limited Program in order to differentiate taxpayers seeking to correct unintentional errors from taxpayers seeking to correct intentional errors.

The CRA’s VDP General Program offers partial interest relief and waives penalties related to corrected issues, while also not referring you for criminal prosecution. In contrast, the VDP Limited Program is intended for taxpayers who made intentional errors to avoid tax obligations. While this program also protects against criminal prosecution and gross negligence penalties, other penalties may still apply, and interest will be charged on amounts owing. The CRA evaluates each VDP application on a case-by-case basis to determine eligibility for the General or Limited Program.

At KR Law Firm, we provide strategic advice and guidance throughout the disclosure process, ensuring that all relevant information is accurately disclosed to the CRA. We also provide representation in the event of any disputes that may arise during the VDP process. If you believe you may have made errors or omissions in your tax reporting, contact our law firm to learn more about how the VDP can help you.

Objections

To dispute the findings of the Canada Revenue Agency (CRA) in a notice of assessment or reassessment, you can initiate the process by requesting an independent internal review of your file by an Appeals Officer at the CRA.

To initiate this process, you must file a Notice of Objection within 90 days of receiving the Notice of Assessment/Reassessment. While extension requests are possible, they are not always granted and must be made within a year of the 90-day objection period ending.

After submitting a Notice of Objection, the CRA will contact you (or your legal representative) and assign an Appeals Officer to conduct an independent review of the disputed amounts.

When objections are raised, the Appeals Officer has three possible outcomes for the reassessment. First, the assessment/reassessment may be vacated, meaning that the Appeals Officer will agree with your legal arguments and will vacate the assessment/reassessment. Alternatively, the assessment/reassessment may be varied, meaning that the Appeals Officer will accept some of your legal arguments, and a new assessment or reassessment will reflect this. Finally, the assessment/reassessment may be confirmed, meaning that the Appeals Officer will dismiss your legal arguments.

If you disagree with the Appeals Officer’s interpretation of the facts, you have the right to appeal to the Tax Court of Canada within 90 days of the CRA’s decision, but it can be extended for up to one additional year through an application to the court.

Our lawyers can assist you with the CRA objection process by reviewing your case and providing legal advice on the best course of action. We can help you gather and present evidence to support your objection and can represent you in negotiations with the CRA. Our lawyers can also appeal the decision to the Tax Court of Canada if necessary.

If you have received a notice of assessment or reassessment from the CRA and disagree with their findings, contact us today to discuss your options for filing a CRA objection.

Objections

Disagree with a tax assessment or decision made by the Canada Revenue Agency? Consult our tax lawyers to understand your rights and explore the process of filing objections to protect your interests.

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Tax Court

Seeking to challenge a decision by the Canada Revenue Agency? Learn how our tax lawyers can provide representation and guide you through the Tax Court process to resolve your tax dispute effectively.

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Tax Court

The Tax Court of Canada (TCC) is an independent court that adjudicates cases related to taxes, including disputes between taxpayers and the Canada Revenue Agency (CRA). If a taxpayer disagrees with a CRA ruling, they may file a Notice of Objection, but if the response takes too long or if they are unsatisfied with the CRA’s decision, they may file a Notice of Appeal with the TCC to begin the process to appeal the decision.

The TCC has two procedures available to taxpayers: the Informal Procedure and the General Procedure. The Informal Procedure is for minor disputes and has a shorter processing time, no filing fee and simpler procedures.

For the Informal Procedure at the TCC, the limit for the amount in dispute per year for federal tax and penalties is $25,000. For Goods and Services Tax (GST) related matters, the limit is $50,000. This means that if the disputed amount does not exceed these limits, the Informal Procedure can be used.

In contrast, the General Procedure is more formal and adheres to the TCC Rules, with deviations allowed only with a court-issued order. The General Procedure requires a filing fee, and the cost varies based on the appeal’s value. Individuals can represent themselves in General Procedure appeals, but corporations must be represented by a legal professional.

Filing a Notice of Appeal usually halts the CRA’s Collections Department from collecting the tax debt during the proceedings, but interest accrues during this time. However, trust fund appeals, such as HST, remain collectible, and it is vital to communicate with the CRA Collections to avoid legal consequences during the Tax Court process.

At KR Law Firm, we offer legal representation for clients who wish to appeal a decision to the TCC. Our lawyers will help prepare your case, present evidence and arguments in court, and navigate the appeals process.

We understand that tax disputes can be complex and stressful, and we work closely with you to provide personalized and effective legal representation. Whether you are a business owner, individual taxpayer, or a professional, we can help you resolve your tax dispute and protect your interests.

Criminal Prosecution

Individuals suspected of tax evasion are subject to the significant investigative and prosecutorial powers of the Canada Revenue Agency (CRA), which can result in fines up to twice the amount of tax sought to be evaded, and imprisonment for a maximum of two years.

The CRA’s Special Investigations division is responsible for investigating cases of suspected tax evasion. If the CRA has reason to believe that a taxpayer has not reported their income accurately or has otherwise engaged in fraudulent activity, they may initiate an audit or investigation. This can involve reviewing the taxpayer’s financial records, conducting interviews with the taxpayer and other relevant parties, and gathering other evidence to build their case.

If the CRA concludes there is enough evidence to warrant criminal charges, the case is referred to the Department of Justice for criminal prosecution under the Criminal Code of Canada.

The CRA has significant powers to investigate and prosecute individuals suspected of tax evasion, and the process of being targeted by the CRA can be an intimidating and overwhelming experience for taxpayers.

If you are the subject of a CRA investigation, our lawyers will help you understand your rights, assist with the investigation, and advise you on how to respond to requests for information and documentation from the CRA. It is critical to have a tax lawyer on your side during this process. We can review the evidence against you, identify weaknesses in the case, and develop a defense strategy tailored to your specific situation. We can also negotiate with the CRA to reduce the charges or penalties you may face.

Criminal Prosecution

Facing potential criminal prosecution for tax-related offenses? Seek legal protection and strategic counsel from our experienced tax lawyers to navigate the complexities of criminal tax matters and safeguard your rights.

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Judicial Review

Disagree with a decision made by a tax authority and seeking a review by the court? Discover how our tax lawyers can guide you through the judicial review process, advocating for fairness and accountability in tax matters.

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Judicial Review

In Canada, administrative bodies hold significant decision-making powers that can impact people’s rights and interests. Judicial review is the process by which courts supervise this decision-making function to ensure it’s fair and within the statutory powers granted to the bodies.

In tax law, the Minister of National Revenue (Minister) is responsible for administering and enforcing and ensuring compliance with Canadian tax laws. In practice, however, the Canada Revenue Agency (CRA) performs nearly all of the Minister’s functions in administering the collection of taxes and enforcement of tax laws. The CRA is, therefore, a government decision-making body and must exercise its powers given to it fairly and according to the tax statutes.

It is important to note that the Courts will only engage in a judicial review of discretionary decisions made by the CRA under tax statutes.

Applications for judicial review of the CRA’s decisions to the Federal Court must be made within 30 days of the date that the decision was communicated to the taxpayer.

The Federal Court will review the exercise of discretion by the CRA to determine whether it was fair and reasonable. If the Federal Court determines that the CRA did not properly exercise its discretion, the Federal Court will refer the decision back to the CRA for reconsideration of the taxpayer’s case to correct the errors set out by the Federal Court.

If you believe that the CRA has made an unreasonable decision in your tax matter, our lawyers can help you navigate the complex and time-consuming judicial review process. We will review the CRA decision and decision-making process, prepare your application and represent you at the Federal Court, giving you the best chance of success with your judicial review application.

Taxpayer Relief

The Canada Revenue Agency (CRA) imposes daily compounded interest and penalties on taxpayers for late payment and filing of taxes. Taxpayers in certain circumstances can request that the CRA reduce or cancel interest and penalties through the CRA’s Taxpayer Relief Program.

The CRA is not authorized to change the primary tax amount via the Taxpayer Relief Program. This program solely provides the option to decrease or waive the interest and penalties associated with the tax.

The Taxpayer Relief Program is only available in certain situations. The CRA will only grant interest and penalty relief in certain situations where circumstances beyond a taxpayer’s control prevented them from paying or filing their taxes on time. While the CRA has the discretion to accept circumstances other than the ones below, the Taxpayer Relief Program is generally available under these three circumstances:

Extraordinary circumstances (If the interest or penalties arose due to circumstances beyond the taxpayer’s reasonable control. This could include, for example, death, severe illness, natural disaster, accidents or mental distress)
Significant financial hardship (If the tax debt to the CRA, including its interest and penalties, is causing substantial financial hardship on the taxpayer, or if the taxpayer has shown an inability to pay the tax debt due to financial hardship)
Actions of the CRA (If the CRA’s actions, for example, processing delays or errors, have caused or contributed to the interest or penalties)

If you believe that you have been unfairly assessed penalties or interest by the CRA, we can help you seek taxpayer relief. Our lawyers can assess your situation and determine if you are eligible for relief. If you are eligible, we will help you prepare a strong case for relief, including gathering and presenting the necessary documentation to support your claim. Taxpayer relief applications have complex requirements and procedures and our lawyers can guide you through the process to ensure that you have the best chance of success.

Taxpayer Relief

Struggling with overwhelming tax debt or penalties? Discover how our tax lawyers can help you navigate the Taxpayer Relief Program for potential solutions to alleviate your tax burdens.

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Tax Debt

Overwhelmed by tax debt? Consult our tax lawyers to explore strategies for managing and resolving your tax obligations effectively.

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Tax Debt

Owing a debt to the Canada Revenue Agency (CRA) is not like any other debt. Unlike other creditors, the CRA has powerful and broad powers under the law that it can use to collect its debt owed to it. In addition, the CRA’s Collections Department is incredibly aggressive in using these powers to collect its debts.

The CRA’s powerful and broad powers to collect tax debts include seizing money from bank accounts, garnishing payroll cheques and seizing and selling personal assets without a court order. The CRA also has the power to issue a “requirement to pay” to third parties that owe you money, instructing them to remit the funds owed to you directly to the CRA.

There is a statute of limitations on tax debt collection by the CRA, which sets a time limit for the CRA to collect taxes owed by a taxpayer. Depending on the type of tax debt, the collection limitation period can be six or ten years. However, there are several methods in which the CRA can “reset the clock” on these limitation periods. This is why it is crucial to be highly vigilant when dealing with the CRA regarding your tax debt.

While the CRA will normally not stop collections actions until the tax debt is paid in full, there are certain situations where the CRA may have to stop its collections actions.

If you can demonstrate that collections actions are causing significant financial harm, or if such actions would deprive your family of the essentials of life, such as food, clothing, and shelter, the CRA may be willing to stop collections. Additionally, the CRA takes into account the impact of collections actions on businesses that create high-quality employment in Canadian society, as part of its informal policy.

If you owe a tax debt to the CRA, it is important to take prompt action to deal with the issue. The longer you wait, the more interest and penalties will accrue on the amount owed, making it more difficult to pay off the debt.

There are a number of options available for taxpayers who owe a tax debt to the CRA. One option is to set up a payment plan, which allows the taxpayer to make regular payments to the CRA until the debt is paid in full. Another option is to make a lump sum payment to pay off the debt in full. It is also possible to negotiate with the CRA to have the interest and penalties waived.

Our lawyers can help you navigate the complex rules and regulations surrounding CRA tax debt collection. We can assist you in negotiating with the CRA to find a solution that works for you and help you avoid further legal consequences.

Remission Orders

Remission Orders provide a potential avenue for relief from tax-related penalties and interest imposed by the Canada Revenue Agency (CRA). Unlike other programs, Remission Orders have the authority to reduce or eliminate the primary tax amount owed.

In specific circumstances, taxpayers can request a Remission Order to seek relief from penalties and interest associated with their tax debt. The CRA has discretionary powers to grant Remission Orders based on various situations, including extraordinary circumstances beyond the taxpayer’s control (e.g., severe illness, natural disasters), significant financial hardship, or actions of the CRA (e.g., processing delays or errors).

If you believe you have been unfairly assessed penalties or interest by the CRA, our experienced tax lawyers can assist you in pursuing a Remission Order. We will assess your eligibility, build a strong case for relief, and guide you through the intricate requirements and procedures involved. By compiling and presenting the necessary documentation, we strive to increase your chances of obtaining the relief you seek.

Remission Orders

Need relief from taxes or penalties? Our tax lawyers can assist you in pursuing Remission Orders, exploring potential avenues for tax relief and navigating the complex process to alleviate your tax obligations.

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Phone: +1 (416) 549 4905 | Fax: +1 (647) 695 2819 | Email: info@krlawfirm.ca
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