A CRA audit or reassessment can create immediate financial and operational pressure. The issues may be technical, information requests may be extensive, and objection deadlines continue to run while you are still trying to understand what happened. Barr LLP represents individuals, corporations, trusts and estates in disputes with the Canada Revenue Agency and in appeals before the Tax Court of Canada. We start by defining the dispute: reviewing returns, assessments, correspondence and supporting records to identify what the CRA decided and what evidence is available, then explaining your procedural options, deadlines, collection risks and likely costs.
CRA audits, reviews and information requests:
- We help you understand the scope of CRA requests, gather responsive documents, protect legal privilege and present the facts accurately.
- We may communicate with the auditor and make legal submissions before a reassessment is issued.
- Our dispute work spans corporate and shareholder transactions, business expenses, unreported income allegations, net-worth assessments, GST/HST, payroll matters, trusts and estates, tax residency, section 160 assessments, and penalties and interest.
Notices of objection:
- A notice of objection asks the CRA’s Appeals Division to review an assessment. It must be filed within the applicable deadline and clearly identify the amounts and issues in dispute, the relief requested, and the reasons for your position.
- We prepare and manage objections, assemble supporting evidence, and respond to Appeals officers, assessing whether issues can be resolved without litigation.
Tax Court of Canada appeals:
- If a dispute is not resolved at the objection stage, you may appeal to the Tax Court of Canada under the informal or general procedure.
- We advise on pleadings, documentary production, examinations for discovery, settlement discussions, motions and trial.
- We identify the evidence needed to meet the burden of proof and test the assumptions underlying the assessment.
Penalty and interest relief:
- In some circumstances the CRA may waive or cancel penalties and interest. Relief is discretionary and requires evidence connecting your circumstances to the delay or non-compliance.
- We help prepare taxpayer-relief requests and, where appropriate, advise on judicial review in the Federal Court.
Tax disputes are easier to manage when advice is obtained early and deadlines are controlled. If you have received a CRA request, proposal letter, assessment or reassessment, we can review the issue and provide a clear plan for the next step.
