Overview
Gowling WLG's Tax Dispute Resolution Group is home to some of Canada's most highly regarded tax dispute advisers. With specialized legal expertise in Canadian tax law, our team will minimize your stress and the time it takes to resolve complex disputes.
Comprehensive service offering
Our team combines broad tax dispute expertise with extensive experience to advise on a range of matters, including with respect to:
- Transaction risk assessment and filing position advice
- Documentary disclosure, written questions and interviews at the audit stage
- Notices of objection
- Appeals to the Tax Court of Canada and the Federal Court of Appeal
- Charity registration and revocation
- Rectification and rescission applications
- Remission order applications
- Taxpayer relief applications
- Judicial review
- Transfer pricing
- Voluntary disclosures
- Competent authority requests under the MAP article of Canada's tax treaties
Whether you're a tax director, chief financial officer, business entrepreneur or a high-net-worth individual with a tax issue, we can help you achieve the best possible outcome at every stage of a tax dispute. While our aim is to short-circuit litigation, we're well-equipped to take your dispute to court.
Experience you can trust
Regularly ranked as leaders in their field by Chambers Canada, Best Lawyers in Canada, International Tax Review, Lexpert Special Edition: Litigation, and the Canadian Legal Lexpert Directory, our professionals have high-level experience in both private and public sectors. Members of our team have served in the Canada Revenue Agency's Income Tax Rulings Directorate, International and Large Business Directorate, Aggressive Tax Planning Division, Legislative Policy Division, and the Canadian Competent Authority Services Division. We write books, we speak at conferences, we teach at law schools and act as thought leaders in the tax dispute resolution space.
Tailored advice
Our professionals have in-depth expertise across a number of sectors – from automotive, cosmetics, energy, mining, infrastructure and life sciences to government affairs, financial services, technology and manufacturing – and are well-positioned to advise on the challenges and opportunities unique to your business.
Client service highlights
Some recent tax disputes wins for our clients include:
- Non-resident internet corporation's GST/HST appeal allowed: Successfully resolved disputes for internet electronic commerce service providers, engaging novel and precedent-setting issues, including whether a non-resident electronic commerce enterprise provided taxable services and was carrying on business in Canada.
- International sporting event tax disputes resolved: Successfully resolved withholding tax reassessments on payments from a Canadian broadcasting company to its foreign parent, involving high-level interrelated negotiations with CRA audit and appeals, the Department of Justice, the Office of the Taxpayers' Ombudsman, and the Department of Finance, in conjunction with an appeal to the Tax Court of Canada.
- Rectified structure for non-resident energy production acquisition: Successfully obtained a rectification order to correct the structure for an acquisition of Canadian clean energy facilities, avoiding unintended adverse tax consequences and involving novel issues, including the complex Income Tax Act subsection 88(1) "bump" rules.
- Non-resident not taxable: Successfully overturned substantial assessments against family members of a high-net-worth foreign national, by convincing the CRA that the individual was not a Canadian resident for tax purposes.
- Vacated extraordinary penalties for offshore investments: Successfully defended taxpayers assessed extraordinarily onerous civil penalties, including under Income Tax Act provisions never previously litigated.
- Helping disadvantaged taxpayers: Gives back to the community by providing pro bono legal help to disadvantaged people, saving marginalized individuals from bankruptcy or poverty by vacating or reducing tax reassessments.
Learn more
If you'd like to ask a tax dispute resolution question on a strictly confidential basis, please contact any member of our team.
