Tax Litigation

You received a letter from the Revenue Quebec or Revenue Canada asking for:


  • Documents?

  • More Information on a tax return?

  • A questionnaire?

  • An appointment for an audit at your home or place of business?


This is the first step in a long process, which works as follows, in order:


  1. Audit;

  2. Reassessment;

  3. Objection to the reassessment;

  4. Appeal of the decision on objection;


This whole process is what we generally refer to as tax litigation. 


The Audit stage, arguably the most important stage, is where the tax authorities decide whether or not to reassess you, depending on what they find.  It is important to deal with a tax professional who can be placed between you and the tax auditor in order to review all documents and answers given to the authorities.  This can make the next steps much easier, and prevent any “incriminating” statements or documents from being produced, which can work against you in the future.


Once the auditor is done his work, assuming he finds some irregularities, undeclared income, etc. he will issue a draft assessment at which point the taxpayer will be able to provide comments and arguments, supported by documentary evidence, in order to reduce or reverse the assessment. 


Note that the auditor is the person who decides to add penalties, which can sometimes almost double the tax bill when combined with interest. 


The next steps are the Objection to the reassessments and finally the Appeal of the decision of the objections officer, in the case where he maintains the reassessments or only partially allows it.  Time limits between steps are extremely important and rigorously applied, contact a professional as soon as you receive the first letter.   


Note that an accountant cannot represent you during the appeal process as he is not a lawyer.  In order to streamline the whole process, is it always preferable that we manage the entire case.  We can work with your accountant if need be. 


Concurrently, you may or may not have to deal with a collections officer, depending on the type of tax debt (for example: DAS, GST, QST, director liability, corp income tax, personal income tax, etc.) who will try to protect and guarantee the payment of the tax debt by putting a lien on your property, freezing an account, asking for a security deposit, cancelling your tax numbers, liquidating a portfolio of stocks, etc.  Most taxpayers don’t know their rights, and we can ensure that these things don’t happen if they don’t have to.


Our team is specialized in this area of law and we provide affordable and efficient services.  Our fees can be negotiated in advance for each step of the process.


Contact us or fill in the form below.

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