Tax Litigation

Whatever the tax issue, Patterson Law’s Tax Litigation team can help.

We help companies, professionals and individuals to navigate and respond to tax disputes.

The Canadian Government provides CRA with the power and resources needed to audit Canadian taxpayers and target activity that CRA considers offensive. More than ever, taxpayers, accountants and advisors, are faced with the daunting prospect of having to defend their actions in the face of a constantly changing tax landscape. Patterson Law provides strategic advice to avoid or resolve tax disputes when they arise and, when necessary, litigate those matters through the courts.

What makes our Tax Litigation Group special is that it operates as a team. Each member of our team is recognized for their skill, knowledge and experience in various aspects related to tax litigation. As a team, that breadth of knowledge ensures that our clients have access to the best people for the job, no matter how complicated the issue.

Our litigators are implacably focused on results in the courtroom, regularly arguing cases at various levels of court, from Provincial Court to Supreme Court to the Tax Court of Canada. As important as our courtroom successes are, our successes outside of court are equally as important. Identifying opportunities to resolve cases without a public hearing,  requires understanding the full range of potential options, including administrative appeals to CRA, negotiations with the Department of Justice and rectification orders designed to  “undo” third party mistakes that have caused unintended tax consequences.

The Patterson Law Tax Litigation Group advises clients on tax disputes relating to issues including:

• Tax Evasion charges
• Income tax, HST and EI objections
• Rectification applications
• Appeals from re-assessment to the Tax Court of Canada
• Voluntary disclosure applications
• Section 160 assessments
• Net worth assessments
• Federal and provincial GAAR and other tax avoidance provisions
• Shareholder benefits
• Gross negligence penalties 
• Disputes with the CRA
• Negotiation with CRA collection officers
• Directors’ liability for HST
• Financial transactions
• Characterization of amounts as income or capital gains
• Shareholder and employee benefits