Tax support for professionals

Tax law research, transaction planning support, and dispute and litigation support for lawyers, accountants, and other advisers, delivered to you for your own file and your own client.

Working with your firm

• The engagement is with you or your firm, not with your client. Deliverables go to you, in a form you can adopt, adapt, or use under your own name.
• We do not contact your client unless you ask us to.
• A conflicts check is completed before you send substantive facts. A confidentiality agreement is available on request.
• Scope, deliverable, timing, and any cap on fees are agreed in writing before work begins.
• A sample memorandum format is available on request.

Research and analysis

• Question-based research memoranda that state the facts assumed, the governing provisions, the authorities, and a stated level of confidence in the conclusion
• Second opinions and peer review of a filing position, a proposed plan, or a draft opinion
• Assessment of exposure to the general anti-avoidance rule (GAAR) and other anti-avoidance provisions
• Analysis of CRA administrative positions and of the current state of the case law, including where it is unsettled
• Briefings on legislative and jurisprudential change for your practice area

Transaction planning and support

• Structuring alternatives and steps memoranda for reorganizations, sales, acquisitions, and succession plans
• Tax-cost modelling of the alternatives
• Tax review of draft transaction documents, with comments for counsel
• Preparation of advance income tax ruling requests
• Tax due diligence for acquisitions and reorganizations
• Post-mortem and estate planning support

Dispute and litigation support

• Merits assessment before your firm accepts a tax dispute
• Chronologies, document briefs, and issue lists
• Research supporting notices of objection, notices of appeal, pleadings, and written argument
• Audit and Appeals Division support behind the scenes
• Preparation for discovery and hearing
• Settlement modelling
• Consulting (non-testifying) assistance to counsel on technical tax questions

Practice support

• Overflow drafting, including white-label drafting of objections and submissions
• Ongoing support on tax files, available by the matter or by the block of hours
• CPD sessions and internal training for your firm
• Precedent banks and checklists built for your practice

Work is billed hourly, at rates that depend on the level of the work, or on a capped fee for a defined research question. Block-hours arrangements are available for firms that use us regularly. Rates are provided on request. To discuss a file, write to info@pariz.ca with your firm’s name, the general nature of the matter, and the names of any adverse parties, without confidential facts, so that we can clear conflicts first.