Our tax lawyers represent individuals and businesses in appeals before the Tax Court of Canada.
When a tax dispute is not resolved through the CRA objection process, a taxpayer may have the right to appeal to the Tax Court of Canada. KR Law Firm represents individuals and businesses in tax litigation involving disputed assessments, reassessments and other matters within the Tax Court’s jurisdiction.
Tax Court proceedings may follow the informal or general procedure depending on the nature of the appeal and applicable rules. The appropriate procedure can affect filing requirements, representation and how the case proceeds.
If you owe tax debt to the Canada Revenue Agency, the CRA may take collection action that can affect your income, bank accounts and assets. KR Law Firm advises individuals and businesses facing CRA collections, significant tax debt and enforcement action, and assists with legal strategy, CRA communications and available payment or relief options.
CRA collection action can escalate when tax debt remains unresolved. Addressing the matter early can help clarify the available options and reduce the risk of additional enforcement measures.
Our tax lawyers advise individuals and businesses facing CRA collections, significant tax debt and enforcement action.
Our tax lawyers advise and represent individuals and businesses throughout the CRA audit process.
A CRA audit can involve a detailed review of an individual’s or business’s tax filings, financial records and supporting documentation. KR Law Firm advises and represents taxpayers during CRA audits, helping them respond to information requests, address disputed issues and protect their legal position throughout the audit process.
The scope and complexity of a CRA audit can vary significantly depending on the taxpayer, the issues under review and the records involved. Obtaining advice early in the process can help ensure that CRA requests are addressed carefully and that potential tax disputes are identified before the audit is completed.
Whether you are dealing with a CRA collection action, tax audit, disputed assessment or Tax Court proceeding, KR Law Firm can review your circumstances and discuss the legal options that may be available.
If you disagree with a CRA assessment or reassessment, you may be able to challenge it by filing a Notice of Objection. KR Law Firm assists individuals and businesses with tax objections involving disputed assessments, reassessments, penalties and other CRA decisions.
Objection deadlines can be strict and vary depending on the taxpayer and type of assessment. In many cases, a Notice of Objection must be filed within 90 days of the assessment or reassessment, although different rules can apply to individuals, trusts and other taxpayers. If the deadline has passed, an extension may be available in certain circumstances.
Our tax lawyers assist individuals and businesses with Notices of Objection and disputes involving CRA assessments and reassessments.
Our tax lawyers assist individuals and businesses with Voluntary Disclosures Program applications involving past tax errors or omissions.
The Canada Revenue Agency’s Voluntary Disclosures Program allows eligible taxpayers and registrants to correct certain errors or omissions in previous tax filings and apply for relief from penalties, part of the interest, and criminal prosecution related to the disclosed information. Any underlying tax owing must still be paid.
The availability and level of relief under the VDP depend on the circumstances of the disclosure, the type of application and whether the CRA considers the application eligible. Seeking advice before submitting a disclosure can help clarify the applicable requirements and potential relief.
Some CRA decisions involve discretionary authority rather than the correctness of a tax assessment. If you believe the CRA did not exercise that discretion fairly or reasonably, you may be able to seek judicial review in the Federal Court. KR Law Firm advises and represents taxpayers in judicial review matters involving CRA discretionary decisions.
A judicial review does not generally allow the Federal Court to replace the CRA’s discretionary decision with its own. If the Court finds that the decision was not properly made, it may set the decision aside and send the matter back to the CRA for reconsideration in accordance with the Court’s reasons.
Judicial review applications are subject to strict time limits. In many CRA discretionary-decision matters, an application to the Federal Court must generally be filed within 30 days of the taxpayer receiving or being notified of the decision, subject to the applicable law and circumstances.
Our tax lawyers represent taxpayers in Federal Court judicial review proceedings involving CRA discretionary decisions.
Our tax lawyers assist individuals and businesses with CRA requests to cancel or waive penalties and interest.
The Canada Revenue Agency has discretion under the taxpayer relief provisions to cancel or waive certain penalties and interest where the applicable requirements are met. KR Law Firm assists individuals and businesses with requests for CRA penalty and interest relief where events beyond their control, CRA actions, financial hardship or other relevant circumstances may support relief.
Penalty and interest relief is discretionary and is not guaranteed. The CRA considers the taxpayer’s circumstances, compliance history, actions taken to address the issue, and the supporting evidence provided with the request.
Real estate transactions can raise significant Canadian tax issues, particularly where the CRA questions how a property sale, rental activity, assignment or principal residence has been reported. KR Law Firm advises and represents individuals and businesses in disputes and compliance matters involving the tax treatment of Canadian real estate.
The tax treatment of a real estate transaction depends on the specific facts, including how the property was acquired, used and ultimately disposed of. Early advice can be particularly important where the CRA is reviewing a property sale or questioning whether a gain was properly reported.
Our tax lawyers advise and represent clients in CRA disputes involving property sales, principal residence claims, assignments and other real estate tax matters.
Our tax lawyers advise individuals on Canadian residency status, residential ties, tax treaties and CRA residency disputes.
A person’s Canadian tax obligations depend in part on whether they are considered a resident or non-resident of Canada for income tax purposes. Tax residency is determined based on the individual’s circumstances, including residential ties to Canada, time spent inside and outside the country, and the possible application of a tax treaty.
Tax residency is highly fact-specific. Maintaining significant residential ties with Canada can result in continued Canadian residency even while living abroad, while establishing or severing those ties can affect when residency begins or ends.
A remission order is a rare and extraordinary form of relief that may provide full or partial relief from federal tax, interest, penalties or other debt administered by the Canada Revenue Agency. Remission is generally considered only where relief may be warranted but cannot be achieved through the ordinary tax rules, an assessment, objection, taxpayer relief provisions or other available remedies.
Remission is not a routine tax-debt solution and is not granted simply because a taxpayer cannot pay an outstanding balance. In most cases, taxpayers are expected to pursue other available remedies before requesting a remission review.
Our tax lawyers advise individuals and businesses on exceptional CRA remission requests and related legal remedies.
Our tax lawyers advise and represent individuals and businesses facing CRA criminal investigations and tax prosecution matters.
CRA criminal tax investigations are distinct from ordinary civil audits and may involve allegations of tax evasion, tax fraud or other serious violations of Canadian tax law. KR Law Firm advises and represents individuals and businesses facing CRA criminal investigations and related prosecution matters.
A CRA criminal investigation is fundamentally different from a civil tax audit. A criminal investigation may lead to prosecution and, upon conviction, court-imposed fines, imprisonment and a criminal record, in addition to taxes and interest that may remain payable.
Effective tax planning can help individuals and businesses understand the Canadian tax consequences of transactions, business structures and other financial decisions before they are implemented. KR Law Firm provides legal advice on lawful tax planning, compliance and the management of potential tax risk.
Tax planning should be based on the specific facts and applicable law. Transactions that are inconsistent with the object, spirit or purpose of the tax rules may be subject to anti-avoidance provisions, including the General Anti-Avoidance Rule, and can result in CRA scrutiny and reassessment.
Our tax lawyers advise individuals and businesses on Canadian tax planning, transaction structuring and potential CRA risks.
Have questions about CRA audits, objections, tax debt, voluntary disclosures, tax residency, or other Canadian tax matters?
Visit our Canadian Tax FAQ for answers to common tax questions.