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Tax Law

• Planning

  • Transfer Pricing and International Tax Issues
  • Tax Residence Issues
  • Tax-Planned Business Reorganizations
  • Trusts
  • Corporate Control and Association Issues
  • Taxation of Executive and Employee Benefits and Termination Packages
  • Succession Planning
  • Investment Structures
  • Property Dispositions
  • Tax Consequences of Marriage Breakdown

• Avoiding Tax Disputes

  • Obtaining CRA Rulings
  • Voluntary Disclosures
  • Requests for Remission of Tax
  • Requests for Consent to Rectification

• Tax Disputes: Audit and Objections

  • Responding to Requests for Information and Documents
  • Responding to Audit Proposals
  • Filing and Negotiating Notices of Objection
  • Preparing Applications for Late-Filed Objections

• Tax Disputes: Court Proceedings

  • Filing and Prosecuting Appeals in the Tax Court of Canada, Federal Court of Appeal and Supreme Court of Canada
  • Filing and Prosecuting Applications for Judicial Review
  • Preparing Applications for Late-Filed Objections and Appeals
  • Filing and Prosecuting Applications and Actions for Court-Ordered Rectification