Tax planning and disputes

For individuals, families, owner-managers, and their corporations: planning that anticipates how the Canada Revenue Agency (CRA) will read a transaction, and dispute work that looks to resolve your issue quickly and effectively.

We regularly work with lawyers, accountants, valuators, and other professionals in Canada and internationally, and will make referrals as needed.

Start with your situation

• You have received a CRA letter, an audit request, or a notice of reassessment. Deadlines to object and to appeal are short and strictly applied, so check the date on the notice first. We review the position, manage the correspondence, and, where it is warranted, file and pursue the objection.
• You are planning a sale, a reorganization, a succession, or a large transaction. We identify what is available, what it costs, and how the CRA is likely to view it before anything is signed.
• You are moving to or from Canada, or you have income or property abroad. We address residency, reporting obligations, and the treaty and foreign-property rules.
• You have a return that should be corrected, or a tax debt you cannot pay. We consider voluntary disclosure, relief from interest and penalties, and a payment arrangement.
• Another adviser has proposed a plan and you want it tested. We review it, including its exposure to the general anti-avoidance rule (GAAR) and any reporting obligations.

Planning

• Owner-manager remuneration, dividends, and surplus extraction
• Corporate reorganizations, estate freezes, and succession planning
• Family trusts, income splitting, and the tax on split income (TOSI), including trust filing obligations
• Purchase and sale of a business: share versus asset sale and the lifetime capital gains exemption
• Estate planning and post-mortem tax planning
• Residency and status determinations
• Real estate: principal residence, the characterization of gains, and GST/HST
• Cryptocurrency, NFTs, and other digital assets
• Severance, retiring allowances, and other employment exits
• Charitable giving, including gifts of property
• GST/HST registration, place of supply, and input tax credits

Disputes

• Audit support: information requests, requirements, and interviews
• Responses to proposal letters and requests for fairness review
• Notices of objection and negotiations with the Appeals Division
• Penalty defence, including gross negligence and foreign-reporting penalties
• Director’s liability for unremitted source deductions and GST/HST
• Section 160 assessments arising from transfers of property
• Preparation for Tax Court of Canada appeals, working with litigation counsel

Relief, disclosure, and collections

• Voluntary disclosures
• Taxpayer relief requests for interest and penalties
• Payment arrangements and responses to collection action, including requirements to pay
• Applications for a remission order, as a last resort where other remedies are not available

Continuing support

• An annual tax review of your position and upcoming decisions
• A pre-audit readiness review of your records and filing positions
• A review of past filings to identify potential errors that may need correction and disclosure
• A standing advisory arrangement for clients who want a knowledgeable adviser available through the year

Most clients begin with an Initial Planning Consultation ($500 plus HST, 60 minutes on Teams), which identifies what planning or dispute work is possible. Full-service work is then billed hourly under a written engagement letter, with a retainer, an estimate for each stage, and your approval before each stage begins. Reduced rates may be available where financial circumstances warrant; please raise this at the consultation. Where your matter fits a defined scope, the fixed-fee services are usually the lower-cost route. To start, write to info@pariz.ca.