Frequently asked questions.

Start with who will actually handle your file. Ask whether a lawyer will represent you, whether your communications will be protected by solicitor-client privilege (accountants and bookkeepers generally cannot offer this), and who your day-to-day contact will be. Privilege matters because anything you tell a non-lawyer representative can later be demanded by the CRA.

Ask about scope and fees up front. Find out whether the engagement is quoted as a fixed fee or billed hourly, what is and is not included, and what happens if the audit expands or proceeds to a Notice of Objection or the Tax Court. At Barrett Tax Law most matters are quoted on a fixed-fee basis once scope is understood, so the cost is known before work begins.

Ask about experience with your specific issue — unreported income, shareholder benefits, a net-worth assessment, GST/HST, or gross negligence penalties — and how the representative plans to preserve your objection and appeal rights while the audit is still open. A representative who is already thinking about the objection stage is protecting your downstream options.

Finally, confirm how deadlines will be tracked. Audit query and proposal-letter deadlines are short, and a missed deadline can narrow your options. A clear answer on how the firm diaries CRA deadlines tells you a lot.

A tax lawyer focuses on the legal side of tax — disputes, litigation, and the structuring of transactions in light of the law and anti-avoidance rules. That includes representing taxpayers in CRA audits and objections, appearing at the Tax Court of Canada, defending penalties and director or derivative liability, and designing reorganizations such as section 85 rollovers and estate freezes.

The most practical distinction is privilege. Communications with a lawyer are generally protected by solicitor-client privilege, while communications with an accountant generally are not and can be demanded by the CRA. Where the facts are sensitive or the matter could become contentious, that protection matters.

Lawyers and accountants often work together — the accountant on the numbers and filings, the lawyer on strategy, privilege, and the legal record. Barrett Tax Law regularly coordinates with a client's existing accountant.

It depends on the stage and complexity of the matter. Narrowly scoped work — a single proposal-letter response, or a straightforward Notice of Objection — can often be handled on a fixed fee. Larger audits and Tax Court appeals, which involve more documents, more issues, and more time, are quoted after we understand the scope.

Barrett Tax Law quotes most matters on a fixed-fee basis after reviewing the file, so you know the cost before work starts. Where a matter cannot reasonably be fixed-fee (for example, an open-ended multi-year litigation file), it is billed hourly with an upfront retainer and a written estimate.

The first consultation is free and without obligation. We use it to understand the issue, explain the likely path, and give you a fee structure in writing so you can decide with full information.

Yes — most matters at Barrett Tax Law are quoted on a fixed-fee basis once we understand the scope of the work. A fixed fee means the price is agreed in writing before the work begins, so there are no surprises as the file progresses.

Some files do not lend themselves to a single fixed fee — open-ended litigation, or audits where the issues keep expanding. Those are billed hourly against an upfront retainer, again with a written estimate so you can budget. We are transparent about which structure applies to your matter and why.

Timelines depend on the procedure and complexity. Informal Procedure appeals typically run twelve to eighteen months. General Procedure appeals typically run eighteen to thirty-six months, and complex matters can take longer because of discovery, motions, and trial scheduling.

On cost, smaller Informal Procedure cases can sometimes be handled for fees in the low five figures. General Procedure cases vary widely with complexity and the length of trial. We provide a written estimate after reviewing the file, and we factor potential costs awards into strategy, since the General Procedure allows costs to be awarded.

A consultation lets us assess your file and give you a realistic sense of both the likely timeline and the fee structure before you commit.

Yes. Most matters qualify for a free, no-obligation consultation with an experienced tax lawyer. The consultation is a chance to describe your situation, get a clear sense of the options and likely path, and receive a fee structure in writing before you commit to anything.

You can reach the firm toll-free at 1-877-882-9829 (1-877-8-TAXTAX) to arrange a confidential consultation. The head office is in Concord, Ontario (Vaughan), and the firm serves clients across Canada.

Yes. Communications between you and your lawyer for the purpose of obtaining legal advice are generally protected by solicitor-client privilege, one of the most strongly protected confidences in Canadian law. In practical terms, the CRA generally cannot compel disclosure of privileged communications.

This is an important difference from working with an accountant or other non-lawyer representative, whose communications and working papers can generally be demanded by the CRA. Where the facts are sensitive — unreported income, offshore assets, or potential penalties — that protection can be significant.

Privilege has limits and can be waived inadvertently, so it should be handled with care. A consultation can explain how privilege applies to your particular situation.

Both have a role, and they are not interchangeable. Accountants are well suited to preparing returns, reconstructing records, and handling routine CRA correspondence. A tax lawyer becomes important when the dispute turns on the law — when penalties are proposed, when the file may proceed to a Notice of Objection or the Tax Court of Canada, or when the matter could expose you to significant liability.

One difference is decisive: communications with a lawyer are generally protected by solicitor-client privilege, while communications with an accountant generally are not and can be demanded by the CRA. Where the facts are sensitive, that protection matters.

In many files the lawyer and accountant work together — the accountant on the numbers, the lawyer on strategy, privilege, and the legal record. Barrett Tax Law regularly coordinates with a client's existing accountant.

It depends on the audit. Many audits are narrow, low-stakes, and document-driven — a query about a specific deduction or receipt — and these are often reasonable to handle yourself by simply providing the records requested. For a small matter, professional fees could exceed the tax at issue, which makes self-representation the sensible choice.

The calculus changes when the stakes and legal complexity rise. A tax lawyer becomes valuable where the CRA is reconstructing your income indirectly (such as a net-worth assessment), where gross-negligence penalties are proposed or foreseeable, where the audit reaches beyond the normal reassessment period, or where the facts are sensitive or carry any criminal potential. In those situations, solicitor-client privilege, control over the scope of disclosure, and framing the law before adjustments harden into an assessment can change the outcome.

A practical middle path is to get a single read early — even on an audit you intend to handle yourself — to confirm it really is routine and to flag the warning signs that would change the answer. Many matters begin self-represented and bring in counsel only if they escalate.

Consider involving a tax lawyer when the CRA proposes penalties (especially gross negligence penalties), when the amounts at stake are large enough to affect your finances, when the file involves multiple years or entities, or when you are approaching a statutory deadline such as the Notice of Objection or a Tax Court appeal.

Getting advice early is usually cheaper than getting it late. A response to an audit query or proposal letter can shape — or quietly damage — your later objection and appeal position. Once a deadline is missed or a damaging admission is made, options narrow.

If you are unsure, a free consultation will tell you whether your matter genuinely needs a lawyer or whether it can be managed another way. We will tell you honestly either way.

Simple disclosures — one tax year, a single tax type, a modest amount — often resolve within roughly six to twelve months of submission. Complex disclosures involving offshore assets, multiple years, or multiple entities can take twelve to twenty-four months or longer.

On cost, simple disclosures can typically be quoted as a fixed fee. Complex, multi-year or offshore disclosures are usually billed hourly with an upfront retainer, with a written estimate provided after the consultation. Separately, the disclosure itself triggers the underlying tax owing plus interest, and any penalties not relieved under the applicable program.

A consultation will give you a realistic sense of both the timeline and the fee structure for your particular situation.

Under a co-counsel arrangement, both professionals stay on the file. You continue to manage the financial statements, the returns, and the routine CRA correspondence; we handle the legal submissions, the strategy, and any Tax Court of Canada proceeding. The client experiences a coordinated team rather than a hand-off.

You can engage us two ways: refer the legal portion of a file to us (we engage your client under our retainer and coordinate with you), or retain us as counsel on behalf of your firm or client. In either structure, the engagement is scoped to the legal work and bounded — you are adding a capability to the file, not transferring it.

No. We work as co-counsel, not as a competitor. We do not prepare returns, we do not provide bookkeeping, and we do not try to convert your client into our client. Your client stays your client.

We step in on the legal side of a specific problem, do that work in coordination with you, and step back out when it resolves. Accountants send us their next difficult file precisely because we return the last client to them intact.

There is no accountant-client privilege in Canadian tax law. Your file, your notes, and your candid communications about a client's position are generally producible to the CRA — and an accountant's working note can become the CRA's evidence.

Once a tax lawyer is engaged, confidential communications made for the purpose of obtaining legal advice are protected by solicitor-client privilege. That protection can extend to analysis prepared at the lawyer's direction for the legal advice. Privilege protects communications made after the lawyer is engaged, so the earlier a lawyer is involved on a sensitive file, the more of the analysis can stay inside the privileged channel.

The legal engagement is scoped to the legal work and quoted up front, so you and your client know what the legal portion will cost before it begins. Many disputes and disclosures are handled on a fixed fee; we tell you the basis of the fee at the outset.

Your own billing for the accounting and return work is unaffected — we do not bill your client for accounting services or insert ourselves into your relationship. The initial consultation is free, and it is available to you as the accountant, not only to the client.

Consider involving a tax lawyer when gross-negligence penalties are proposed, when the amounts are large relative to the client's solvency, when a realistic outcome involves the Tax Court of Canada, when a voluntary-disclosure question is in play, when director's liability or section 160 is in the picture, when solicitor-client privilege would help, or when an auditor's questions hint at criminal exposure.

When two or more of those are present, the file is usually best handled as a coordinated accountant-and-lawyer matter. If you are unsure, a free consultation lets us size up the file with you before anything escalates.

Start with a free consultation — for you, not only your client. Call us or book a consult to talk through the file before anything escalates, with no fee and no obligation, and we will figure out together whether the matter warrants legal involvement and which engagement structure fits.

If it warrants legal work, we scope and quote it; if it does not, we tell you that too. Throughout, you keep the client relationship and stay the day-to-day point of contact. See the For Accountants page to start a conversation.

Not every collections call needs representation, but several signals make professional involvement worthwhile: the debt is large relative to your means and the arrangement being discussed is not sustainable; the underlying assessment may be wrong; the CRA has begun or threatened enforced collection such as a requirement to pay, an account freeze, or a charge on property; interest and penalties have made the debt unaffordable; or there is related exposure such as director's liability or a section 160 assessment.

Once a representative is authorized, the CRA deals with the representative rather than contacting the taxpayer directly, which allows the file to be handled on a considered basis rather than on the spot during a difficult call.

File a Notice of Objection once the CRA has issued a Notice of Reassessment (or certain determinations) that you disagree with. The objection is the formal, statutory route to dispute the CRA's decision, and it is generally the necessary gateway to a later appeal at the Tax Court of Canada — you usually cannot appeal to the Tax Court without first having objected.

Do not wait. The objection deadline is strict, and the quality of the objection matters: a bare-bones form preserves the deadline but a substantive submission setting out the facts and legal arguments is what gives the file its best footing. Filing an objection also moves the file to a more senior CRA Appeals officer who reviews it independently of the auditor.

If you are close to the deadline, act immediately — even a few days can matter.

For individuals, the deadline is the later of 90 days from the date on the Notice of Reassessment, or one year from the original return's filing-due date. For corporations, the deadline is 90 days from the date of the reassessment. For GST/HST, the objection must be filed within 90 days of the date of the assessment.

If the deadline is missed, an application for an extension of time may be available under section 166.1 of the Income Tax Act (with a parallel rule for GST/HST), but it must be brought within one year after the original deadline, and you must satisfy the statutory grounds. The CRA's position on late extensions is strict, so a strong supporting record is needed.

Because a missed objection deadline can end an otherwise winnable case, the safest course is to treat the deadline as firm and act well before it.

After the CRA confirms a reassessment (or 90 days have passed since you filed a Notice of Objection without the CRA acting on it), you have 90 days to file a Notice of Appeal with the Tax Court of Canada. As with the objection, this deadline is statutory and firm.

If the 90-day appeal deadline is missed, a late appeal may be brought under section 167 of the Tax Court of Canada Act, but the threshold is demanding and there is an outer time limit. Relying on a late application is far riskier than meeting the original deadline.

In almost all cases, you must have filed a Notice of Objection before you can appeal to the Tax Court. If a confirmation has arrived, the clock is running — treat the 90 days seriously.

A Notice of Objection is an administrative step within the CRA. It is a written submission telling the CRA you disagree with a reassessment, and it sends the file to a CRA Appeals officer — a more senior CRA employee than the auditor — to review independently. Many disputes are resolved, in whole or in part, at this stage.

A Tax Court appeal is the next step, taken to an independent court rather than to the CRA. It becomes available after the CRA confirms the reassessment, or after 90 days have passed without the CRA acting on the objection. You generally must have filed an objection first before you can appeal.

The two stages also differ in nature. The objection is largely a paper review by the CRA; the Tax Court hears the matter afresh on the evidence, with pleadings and procedure resembling other litigation. Building a strong objection early often improves the position if the matter later proceeds to court.

Yes. A GST/HST assessment under the Excise Tax Act is appealed to the same Tax Court of Canada that hears income-tax appeals. You first file a Notice of Objection within ninety days of the assessment. If the CRA confirms the assessment, or does not decide the objection within one hundred and eighty days, you can take the matter to the Tax Court. Note that the wait before you can go to Court is 180 days for GST/HST, compared with 90 days for income tax.

Once filed, your file is transferred from the auditor (or determination officer) to a CRA Appeals officer, who reviews it independently. We make written submissions, and often oral submissions, setting out the facts, the documentary support, and the legal arguments for your position.

Many objections are resolved through full or partial settlement at the Appeals stage. We assess any settlement offer realistically against the odds and costs of proceeding to the Tax Court of Canada and advise you clearly on the trade-offs.

If the CRA confirms the reassessment and the result is not acceptable, the next step is a Tax Court appeal, which must be filed within 90 days of the confirmation. If the result is acceptable, the file closes.

No. GST/HST is a trust amount — tax you collected from customers on the government's behalf — and the collections pause that applies to disputed income-tax assessments does not apply to it. The CRA can collect a disputed GST/HST assessment while your objection or appeal is still alive. This is one reason registrants with a clearly wrong GST/HST assessment sometimes go straight to the Tax Court once the 180-day waiting period has passed, to compress the timeline.

It depends on the type of taxpayer and tax. For most individual income tax assessments, the CRA generally pauses active collection of the disputed amount while a Notice of Objection or a Tax Court appeal is in progress. That pause is one practical benefit of objecting promptly.

The pause does not apply across the board. For large corporations, the CRA can collect a portion of the disputed amount even during a dispute, and for certain amounts — notably GST/HST and payroll source deductions held in trust — collection can continue despite an objection or appeal.

Because the rules differ by situation, it is worth confirming which collection protection applies to your specific assessment, and addressing any active collection action in parallel with the dispute.

Possibly. If the standard objection deadline has passed, you can apply for an extension of time under section 166.1 of the Income Tax Act (and the parallel GST/HST provision). The application must be made within one year after the original deadline expired.

To succeed, you generally must show that you intended to object within the deadline, that you were unable to act or instruct someone to act for you, and that it is just and equitable to grant the extension — supported by a credible record of the circumstances. The CRA applies these grounds strictly.

Because the one-year outer limit is itself a hard cutoff, do not delay. If that window has also closed, other avenues — such as taxpayer relief for interest and penalties — may still be worth assessing.

It depends on the type of debt. Objecting to an income tax assessment — personal or corporate — applies a "stall code" in the CRA's system: collections action that has started will stop, and action that has not yet begun will not start, while the amount is in dispute.

Trust amounts are different. Objecting to a GST/HST or source-deduction assessment does not stop collections, so a trust debt remains fully collectible even while it is being disputed. For that reason, a clearly incorrect GST/HST assessment can take a year or two to correct while the disputed amount is being collected — one reason taxpayers sometimes choose to skip the appeals officer and go straight to the Tax Court of Canada on trust-debt files.

Yes, after a waiting period. For income tax matters, once 90 days have passed since you filed your notice of objection, you can appeal directly to the Tax Court of Canada without waiting for an appeals officer to decide. For GST/HST matters, the waiting period is 180 days from the filing of the objection.

Skipping ahead can save considerable time, and it is especially useful for a GST/HST assessment that is incorrect but remains collectible while in dispute. The Tax Court also applies the rules of evidence, which the CRA can sidestep at the audit and objection stages — so a well-documented case that stalled inside the agency often fares better before a judge or with Department of Justice counsel.

A Requirement to Pay (RTP) directs a third party who owes you money to send those funds to the CRA instead of to you. Issued to a customer, a trade RTP can capture up to 100% of the receivable and also reveals your tax difficulties to your own clients. Issued to a bank branch, an RTP freezes that account and forwards the balance to the CRA. A wage garnishment is technically an RTP sent to an employer, usually capped between 30% and 50% so the taxpayer can still meet living costs.

RTPs can often be reduced or lifted through negotiation, typically in exchange for a regular voluntary monthly payment. Be cautious about giving a collections officer your accounts-receivable list, because an RTP sent to each customer can stop a business's cash flow almost overnight.

Yes. Under subsection 160(1) of the Income Tax Act (and subsection 325(1) of the Excise Tax Act), if a tax debtor transfers property to a non-arm's-length person — a spouse, child, sibling, or related corporation — for less than fair market value, the recipient can be assessed for the transferor's tax, up to the benefit received. Transfer a $20,000 car for $1 and the recipient received a $19,999 benefit and can be assessed for up to that amount.

There is a hidden danger: even if the transferor owed no tax on the date of the transfer, the CRA can later reassess them for an earlier year, and that liability is treated as having existed retroactively — so the recipient can still be pursued. Because there is no due-diligence escape from a debt that did not yet exist, it is important to get advice before any transfer of property between related parties.

Yes. A Tax Court general-procedure judgment can be appealed to the Federal Court of Appeal, generally within thirty days of the judgment (July and August are not counted in the computation). The deadline is strict; missing it requires an application to extend time, which is not assured. Because the window is short, the decision whether to appeal has to be made quickly, while the trial is still fresh.

No — it is not a retrial. The Federal Court of Appeal reviews the Tax Court's decision for error under a standard of review that depends on the type of question. Questions of law (how the Income Tax Act was interpreted, the legal test applied) are reviewed for correctness. Questions of fact are reviewed only for "palpable and overriding error," a demanding standard that gives deference to the trial judge who heard the witnesses. An appeal that is really a complaint about how the evidence was weighed usually fails; an appeal that identifies a genuine legal error has a real prospect.

For most income tax and GST/HST disputes, yes. The Notice of Objection filed with the CRA is the mandatory first step, and it preserves your right to appeal. You can appeal to the Tax Court only after the CRA confirms or reassesses in response to your objection, or after 90 days have passed since you filed the objection with no decision.

Skipping the objection stage is a common reason appeals get blocked, so if you have not objected yet, start there.

The CRA has a discretion under the taxpayer relief provisions (subsection 220(3.1) of the Income Tax Act) to cancel or waive interest and penalties where the circumstances justify it. The recognized grounds are extraordinary circumstances beyond the taxpayer's control, delay or error on the CRA's part, and inability to pay or financial hardship. The relief reaches interest and penalties only — it does not reduce the underlying tax, which must be disputed through an objection or appeal.

The decision is discretionary, so a well-documented request that ties the facts to a recognized ground is far more likely to succeed than a bare assertion.

The standard form is Form RC4288, "Request for Taxpayer Relief — Cancel or Waive Penalties and Interest." It asks the taxpayer to identify the years and amounts, select the grounds relied on, and explain the circumstances. The explanation is the heart of the request, and it should be supported with documentation — medical records, a death certificate, correspondence showing CRA delay, or financial statements for a hardship claim, depending on the ground.

If the request is denied or granted only in part, a second-level administrative review is available, and a relief decision can ultimately be challenged by judicial review in the Federal Court.

A tax debt does not attach to property on its own. The CRA first certifies the unpaid amount and registers a certificate in the Federal Court under section 223 of the Income Tax Act, which then has the force of a court judgment. With that judgment, the CRA can register a charge against the taxpayer's real property in the relevant provincial land registry. The charge — often called a tax lien — binds the property and must be addressed before the owner can sell or refinance with clear title.

Generally no. A collections officer's role is to collect a debt the CRA has already assessed, not to re-examine whether the tax is owed. If you believe the assessment is wrong, the remedy is a notice of objection (and, if needed, an appeal to the Tax Court of Canada), not a debate with the collections officer. Arguments about the merits of the assessment usually accomplish little on a collections call, because resolving the validity of the debt is not the officer's job.

The Voluntary Disclosures Program applies five tests. The disclosure must be voluntary (the CRA has not already started an enforcement action against you or a related person about the matter — the most commonly failed test), complete (all years, entities, related parties, and tax types), and it must involve a penalty. There must also be information that is at least one year past due, and the applicable tax must be paid or a payment arrangement made.

Whether you qualify for the General Program (broader relief, including no gross negligence penalty and partial interest relief) or the Limited Program (narrower relief) depends on the facts, including whether the conduct involved intentional behaviour.

The eligibility analysis is fact-specific and time-sensitive, because voluntary status can be lost the moment the CRA makes contact. A confidential consultation can confirm whether your situation still qualifies and which program is realistic.

The Voluntary Disclosures Program has two tracks. The General Program offers fuller relief: no gross negligence penalties on the disclosed amounts, relief from criminal prosecution for the disclosed matters, and partial interest relief. It is intended for taxpayers whose non-compliance was not the result of intentional conduct.

The Limited Program offers narrower relief — protection from criminal prosecution and from gross negligence penalties, but other penalties may still apply and there is no interest relief. It is generally directed at situations involving an element of intentional conduct or larger, more sophisticated non-compliance.

Which track applies turns on the facts, and the framing of the application matters. The underlying tax owing and interest are payable under either program.

If a disclosure is accepted under either the General or the Limited Program, the CRA does not refer the disclosed matter for criminal prosecution. That protection is one of the central benefits of coming forward voluntarily rather than waiting to be found.

The protection applies only to the matters actually disclosed. It does not cover issues left out of the disclosure, which is one reason completeness — including all years, entities, and tax types — is essential. An incomplete disclosure can be rejected and can leave undisclosed matters exposed.

Because the stakes include criminal exposure, the eligibility and completeness analysis should be done carefully before anything is filed.

Yes. Undisclosed offshore income and assets, and missed Form T1135 (Foreign Income Verification Statement) filings, are among the most common subjects of voluntary disclosures. Form T1135 is required where the cost of specified foreign property exceeds the $100,000 threshold, and missed filings carry their own penalties.

Offshore disclosures are often multi-year and may involve coordinated personal, corporate, and trust filings, so completeness is especially important. Where there is a parallel US filing obligation, the Canadian disclosure can be coordinated with the US side so both jurisdictions are addressed together.

As with any disclosure, the matter must still be voluntary — assessed before the CRA makes contact. Given the penalties that attach to offshore non-compliance, early advice is worthwhile.

Generally yes, as long as the CRA has not yet contacted you about the matter you wish to disclose, the disclosure is voluntary, complete, and at least one year overdue, and involves a penalty.

The Streamlined Foreign Offshore Procedures are an IRS program for US persons living outside the United States who fell out of compliance with US filing obligations without intending to. The submission consists of three years of amended income tax returns, six years of FBARs, and a signed certification that the conduct was non-willful.

To qualify, the taxpayer must be a non-US-resident in at least one of the three relevant years, must not already be under IRS examination or criminal investigation, and must be able to certify truthfully that the non-compliance was non-willful — that is, due to negligence, inadvertence, mistake, or a good-faith misunderstanding of the law. Where the conditions are met, the program is generally penalty-free.

The non-willful certification is the central document, and an inaccurate one carries serious consequences, so the facts should be assessed carefully before filing. Where the Canadian side also has unreported income, the package is often coordinated with a Canadian voluntary disclosure.

If the CRA discovers the issue first, you face gross-negligence penalties (up to 50% of the tax owing), full interest, and potential criminal prosecution for tax evasion under section 239 of the Income Tax Act.

Drafting takes 2–6 weeks for most cases. CRA review typically takes 6–18 months. Interest continues to accrue until the file closes, but penalties and prosecution are off the table once you have an acknowledgement letter.

Start by taking stock before you file anything. Work out how many years are unfiled, whether there is unreported income behind them or only unfiled returns, and whether the Canada Revenue Agency has already contacted you about the issue. Those three facts determine your strongest route. Where there are balances owing or unreported income and the CRA has not yet reached you, the Voluntary Disclosure Program is worth examining first, because it offers penalty relief, partial interest relief, and protection from prosecution. Where the years would produce refunds or nil balances, simply filing them is usually enough.

The order matters: if the VDP applies, the disclosure is made before the returns are filed, because catching up by filing first can be treated as non-voluntary and forfeit the relief.

For the overwhelming majority of non-filers, no. Most non-filing is handled entirely within the civil system through penalties, assessments, and collections. Prosecution is reserved for a narrow band of conduct. Failure to file under subsection 238(1) is a summary offence that can carry a fine and, in persistent cases, up to twelve months' imprisonment, but it is pursued sparingly. Tax evasion under subsection 239(1) — which requires a deliberate intent to evade — is the serious charge, and simply being behind on filing is not evasion.

The surest way to take the prosecution branch off the table is to come forward first. A valid disclosure under the Voluntary Disclosure Program provides protection from prosecution for the disclosed conduct.

Often, yes — unfiled returns are one of the most common reasons people use the program. The Voluntary Disclosure Program rests on four conditions: the disclosure must be voluntary, complete, involve a penalty, and be at least one year overdue. Unfiled returns that carry balances owing fit the program well, because the late-filing penalty supplies the penalty condition and the overdue returns supply the timing condition.

The condition to watch is "voluntary." Once the CRA issues a demand to file or otherwise contacts you about the unfiled years, the disclosure may no longer count as voluntary and the relief can close. Our step-by-step VDP eligibility guide walks through all four conditions.

A section 85 rollover is an election under the Income Tax Act that lets a taxpayer transfer eligible property to a Canadian corporation on a tax-deferred basis, rather than triggering an immediate capital gain. The transferor and corporation jointly elect an "elected amount" that sets the proceeds for the transferor and the cost for the corporation, typically deferring the accrued gain.

It is commonly used to incorporate a sole proprietorship, to transfer appreciated assets or shares into a holding company, and as a building block in estate freezes and other reorganizations. In exchange for the property, the transferor usually takes back shares (and sometimes a limited amount of non-share consideration).

The election is technical and timing-sensitive — it is made on Form T2057 by a deadline, and errors in the elected amount or the consideration can defeat the deferral or attract adverse consequences. Careful structuring and documentation are essential.

The Lifetime Capital Gains Exemption (LCGE) lets eligible individuals shelter a substantial amount of capital gain — into the millions of dollars and indexed over time — realized on the sale of qualified small business corporation (QSBC) shares, or qualified farm or fishing property. For many business owners it is the single most valuable relief available on a sale.

To use it on a share sale, the shares must meet the QSBC tests at the time of sale: broadly, the company must be a small business corporation using substantially all of its assets in an active business in Canada, the shares must have been held by the seller (or a related person) for the prior 24 months, and an asset-use test must be met throughout that period.

Many companies do not satisfy these tests by default, often because of excess investments or cash. Advance planning — sometimes called "purification" — can position a company so the shares qualify when a sale eventually happens, and the exemption can sometimes be multiplied across family members.

Generally only half of a qualifying meal or entertainment expense is deductible. If you take a client to dinner, you can claim the meal, but the deductible portion is 50%, and the expense has to be reasonable and connected to earning business income.

Meals and entertainment are a frequent audit target because they are so often over-claimed. To support the claim, keep the original receipt and a note of who the client was and the business purpose of the meal. If you cannot provide that context during an audit, the auditor can disallow the expense. Different rules can apply to meals while travelling for business.

An estate freeze is a tax-planning strategy that locks in the current value of an owner's interest in a business (or other appreciating asset) for tax purposes, so that any future appreciation accrues to the heirs or successors rather than the owner.

The owner typically exchanges their common shares for fixed-value preferred shares equal to the current fair market value of the business, and new common shares — which capture future growth — are issued to the next generation or a family trust. The owner's eventual deemed-disposition tax on death is then capped at the frozen value, and the owner can keep control by holding voting preferred shares.

It depends on your numbers and your tolerance for risk. A sole proprietorship is the quickest and least expensive structure to start and run: there is no separate tax return, and you simply report the business profit on your personal T1. The trade-offs are that all of the profit is taxed in your hands in the year it is earned, and there is no liability shield — if the business is sued, you are sued.

A corporation is a separate legal person. It can shield your personal assets from most business liabilities, and a qualifying Canadian-controlled private corporation pays a much lower rate on active business income up to $500,000 (roughly 12.2% in Ontario), which lets you leave surplus profit in the company on a tax-deferred basis. A useful rule of thumb: if your business reliably earns more than you need to live on, a corporation is often the sensible choice; if there is no surplus at month-end, the simplicity of a proprietorship may win.

A free consultation can help you weigh the structures against your actual situation before you commit.

An estate freeze is a reorganization that "freezes" the current value of a business owner's shares at today's value, so that future growth accrues to the next generation or to a family trust. The owner typically exchanges their common shares for fixed-value preferred shares (often using section 85 or section 86), and new common shares are issued to children or to a trust.

The purpose is usually succession and tax planning: it caps the owner's tax exposure on death at the frozen value, shifts future growth to the successors, and can multiply access to the Lifetime Capital Gains Exemption across family members where the structure qualifies. It can also support income-splitting where the tax-on-split-income rules permit.

An estate freeze is a significant, fact-specific reorganization that must be coordinated with corporate law, family circumstances, and the relevant anti-avoidance rules. It should be designed and documented carefully.

The small business deduction reduces the corporate tax rate on active business income earned by a qualifying Canadian-controlled private corporation. It applies to active business income up to $500,000 a year and brings the effective rate down to roughly 12.2% in Ontario — well below the personal marginal rates that would apply if you earned the same income personally.

The saving is largely a deferral. If your corporation earns $100,000 after expenses and you only need to draw $66,000 to live on, you can leave the remaining $34,000 in the company taxed at the low corporate rate. The portion that would otherwise have gone immediately to the Canada Revenue Agency at your high personal rate instead stays in the corporation to reinvest. When the money is eventually paid out to you, it is taxed in your hands then — so the tax is deferred, not eliminated, but the deferred amount works for the business in the meantime.

"Surplus stripping" refers to arrangements that try to extract a corporation's retained earnings as lower-taxed capital gains rather than as higher-taxed dividends. Section 84.1 of the Income Tax Act is an anti-avoidance rule aimed at certain non-arm's-length share transfers that would otherwise convert dividends into capital gains, and it can recharacterize the result as a deemed dividend.

The rule frequently arises in family succession — for example, when a parent sells shares of the family company to a corporation owned by their children. Recent legislation created defined exceptions for genuine intergenerational business transfers that meet specific conditions, but those conditions are detailed and must be satisfied to obtain the relief.

Because the line between legitimate planning and offside surplus stripping is technical and shifting, transactions in this area should be structured with current rules and the general anti-avoidance rule firmly in mind.

Qualifying for the Lifetime Capital Gains Exemption on a share sale requires meeting the qualified small business corporation tests, and a common obstacle is having too many non-active assets — surplus cash, investments, or redundant real estate — on the company's books. "Purification" is planning that removes or repositions those assets so the active-business tests are satisfied.

Typical steps include paying out excess cash, moving passive investments to a separate holding company, and ensuring the company keeps substantially all of its assets in an active business in Canada. Because the tests look back over a 24-month period, this planning generally needs to be done well before a sale, not on its eve.

Where the structure permits, the exemption can sometimes be multiplied among family members through a family trust or direct shareholdings, subject to the tax-on-split-income rules. The earlier this is planned, the more options remain available.

A family trust holds property for the benefit of family members under the control of trustees. In tax and estate planning it serves several purposes: it can hold the growth shares in an estate freeze so future growth accrues outside the founder's estate, it can multiply access to the Lifetime Capital Gains Exemption among beneficiaries, and it can provide flexibility in how and when value reaches the next generation.

Trusts also have important limits and rules. The tax-on-split-income rules restrict income-splitting with certain family members, the 21-year deemed-disposition rule requires planning to avoid a tax hit at that anniversary, and attribution rules can apply where property is transferred to a spouse or minor children.

A trust is a powerful tool when it fits the family's goals, but it adds administration and must be set up and maintained correctly. Whether one is appropriate depends on the specific facts and objectives.

To qualify for the exemption on the sale of Qualified Small Business Corporation shares, three tests must be met. First, the corporation must be a Canadian-controlled private corporation at the time of sale. Second, the asset-use tests must be satisfied: throughout the 24 months before the sale, more than half of the corporation's assets must have been used in an active business carried on primarily in Canada (the 50% test), and at the time of sale a substantial majority of its assets must be so used (the 90% test). Third, the shareholder must have held the shares for at least 24 months continuously before the sale.

If your corporation will have more than one shareholder, a unanimous shareholders' agreement is close to essential. It governs what the shareholders can and cannot do, provides dispute-resolution mechanisms, sets the votes needed for major decisions, and controls how shares can be transferred or pledged. It can also include provisions that force minority shareholders to sell alongside the majority in a takeover, or that let shareholders participate in a deal another shareholder is making.

The single most important thing about a shareholders' agreement is timing: negotiate and sign it while the business is new and the shareholders are still on good terms. It is far harder to agree on these rules after a dispute has already started. We can help prepare an agreement that fits your corporation.

When a shareholder of a private corporation dies, the same underlying value can be taxed more than once: first as a deemed disposition of the shares on death, and again when the corporation's value is later distributed to the estate or heirs. Post-mortem planning is designed to reduce or eliminate that potential double — or even triple — taxation.

Common techniques include the "pipeline" strategy and the subsection 164(6) loss carryback, each suited to different situations and each with its own conditions and timing. The subsection 164(6) approach, for instance, generally must be implemented within the estate's first taxation year.

Because the relief depends on acting within strict deadlines after death, executors and beneficiaries of private-company estates should obtain advice early — well before the first anniversary of death — to preserve the available options.

Yes, if it is done properly. Paying a reasonable salary to a spouse or children who genuinely work in the business shifts income from a higher tax bracket to a lower one and lowers the family's overall tax. If a child with no other income earns a modest wage, they may pay little or no tax on it.

Two conditions are essential. The wage must be reasonable under section 67 of the Income Tax Act — pay what you would pay a stranger for the same work — and the work must be real, with timesheets and a record of what was done. Anything beyond a reasonable salary for genuine work, such as sprinkling dividends to family, can trigger the tax-on-split-income (TOSI) rules, so get advice before going further.

A section 85 rollover lets a taxpayer transfer assets — such as real estate, equipment, or shares — to a corporation in exchange for shares without an immediate tax bill. It requires a joint election by the transferor and the corporation on Form T2057, and the elected amount must fall between the asset's cost base and its fair market value.

A section 86 reorganization, by contrast, is an exchange of all the shares of one class for shares of another class within the same corporation. It is the provision most often used to carry out an estate freeze, and it applies automatically when the conditions are met rather than requiring a joint election.

An estate freeze locks in the current value of a business owner's shares for tax purposes and shifts future growth to the next generation, usually through a family trust. The owner exchanges their growth-bearing common shares for fixed-value preferred shares equal to today's value, and new common shares are issued to children or a family trust to capture future appreciation.

The benefit is that the owner's capital gain on death is capped at today's value rather than the much larger future value, while the post-freeze growth accrues to the next generation outside the owner's estate. A freeze also sets up the family trust to multiply the lifetime capital gains exemption across several beneficiaries on a future sale. A freeze caps the tax rather than eliminating it, and it has to be structured and documented carefully, so it is planning to undertake with professional advice well before a sale or transition.

A corporation is a separate legal person, and active business income earned in a Canadian-controlled private corporation — up to the small business limit, currently $500,000 a year — is taxed at a much lower rate than the same income earned personally. If you do not need to draw all the profit out, the difference stays in the corporation.

The tax is not eliminated; it is deferred until the money is paid out to the shareholder and taxed in their hands. But deferral has real value. The money that would otherwise have gone to tax can be invested or used to grow the business in the meantime, and a dollar of tax paid years from now costs less, in real terms, than a dollar paid today.

Both are valid, and each has trade-offs. Salary puts you on the corporation's payroll: it triggers CPP, sometimes EI, and payroll administration, and it requires the corporation to withhold and remit your source deductions — but it generates RRSP room and is a deductible expense for the corporation. Dividends are paid out of after-tax corporate income and avoid payroll mechanics and CPP, but you must leave enough money in the company to pay its corporate tax at year-end.

A caution applies to both. If a corporation pays dividends while it has unpaid corporate taxes, the Canada Revenue Agency can assess the dividend recipients for that unpaid tax. And if you go on payroll but fail to remit source deductions, you can be assessed as a director. As a sole shareholder and director you can be assessed personally either way, so the corporation's own tax obligations should always be funded first. We can help you plan a mix that fits your situation.

An estate freeze caps the value of a business owner's shares at today's value so that future growth accrues to the next generation. The owner exchanges their common shares for fixed-value preferred shares, and the corporation issues new common shares — usually worth a nominal amount — to children or a family trust. Because the new shares start at nominal value, there is no taxable event when they are issued.

After the freeze, future growth accrues to the next generation's shares, and the tax on that growth is paid much later, when they eventually sell. Because of the time value of money, paying that tax decades from now is far cheaper in real terms than paying it on the owner's death. A freeze can attract CRA scrutiny, so a proper valuation — ideally by a certified business valuator — and a price-adjustment clause are commonly used.

Corporate-owned life insurance is a policy a corporation takes out on the life of a key individual, with the corporation paying the premiums and receiving the death benefit. It serves several purposes: providing a financial safety net for business continuity if a key person dies; funding buy-sell agreements so a deceased shareholder's interest can be purchased without straining the company; and, with a whole-life policy, accumulating cash value on a tax-deferred basis.

A further advantage is that, on the death of the insured, the death benefit received by the corporation (less the policy's adjusted cost basis) can be credited to the corporation's Capital Dividend Account and then distributed tax-free to shareholders.

Where possible, sellers usually prefer to sell shares rather than assets, because the Lifetime Capital Gains Exemption can shelter a gain on qualifying shares but not on a sale of assets. The complication is that buyers often prefer asset sales, which are cleaner and avoid inheriting the company's historical liabilities.

To use the exemption on a share sale, the shares generally have to meet the qualified small business corporation tests at the time of sale, which can require advance planning — sometimes called purification — to remove non-active assets such as excess cash. Because the structure drives the after-tax result, it is worth modelling both options well before a sale rather than after a deal is signed.

Crystallization means triggering a capital gain on paper — without an actual sale to a third party — so you can use your Lifetime Capital Gains Exemption now, before a possible increase in the asset's value or a change in the law reduces the amount available.

It is usually done by valuing the qualifying shares and electing (commonly under a subsection 85(1) rollover) to a deemed disposition at fair market value, then sheltering the resulting gain with the exemption. This resets the cost base of the shares to their current value, so less gain is taxable on an eventual sale, and it locks in today's exemption limit.

It can be. If your corporation provides services that an officer or employee of the client would normally perform, and you function much like one of the client's employees — same work, under their direction, without genuine independence — the Canada Revenue Agency can treat your corporation as a "personal services business." Where that designation applies, the corporation loses the small business deduction and most of its deductions are denied, which can dramatically increase the tax.

The agency looks at the substance of the relationship, not just the fact that you have a corporation: your financial risk, who controls how the work is done, who supplies the tools, and whether you could send a replacement. Workers in industries that encourage incorporation, such as trucking, are especially exposed. If you are concerned that you may be operating a personal services business, it is worth getting advice before an audit raises the issue.

There is no single right answer — it depends on your goals and your corporation. Because the Canadian system is built on integration, the headline tax on salary and dividends is roughly similar; the decision usually turns on the side-effects. Salary is deductible to the corporation, builds RRSP contribution room, and requires CPP contributions (and gives CPP entitlement). Dividends are paid from after-tax corporate profits, attract a lower personal rate through the dividend tax credit, avoid CPP, and create no RRSP room.

Salary tends to suit owners who want RRSP room, value CPP coverage, or need to reduce corporate income to manage the small-business-deduction limit. Dividends tend to suit owners who want to avoid the CPP cost, prefer flexible distributions, or value simpler administration. Most owner-managers use a deliberate blend rather than one route exclusively.

The right mix depends on your income, your retirement-savings plans, your CPP views, the corporation's dividend pools, and your family situation, so it is worth modelling each year as part of year-end planning.

Income splitting through a private corporation is still possible, but the tax-on-split-income (TOSI) rules introduced in 2018 sharply restricted it. TOSI applies the top marginal rate to "split income" — such as dividends — received by a related family member from a private corporation, unless a specific exclusion applies.

The exclusions are what make splitting work. The most important include the excluded-business exclusion for family members who work an average of at least 20 hours a week in the business (or did so in any five prior years), the excluded-shares exclusion for a shareholder aged 25 or older who owns at least 10% of the votes and value of a qualifying corporation, and the exclusions tied to a business owner reaching age 65 and their spouse. Where an exclusion applies, the family member is taxed at their own graduated rates; where none does, TOSI claws the benefit back.

Because the exclusions are technical and fact-specific, splitting has to be built deliberately around them rather than assumed. Getting the analysis right before paying dividends to family members is what keeps the planning onside.

A holding company (holdco) is a corporation that owns the shares of an operating company rather than carrying on the active business itself. Surplus cash earned in the operating company is moved up to the holdco as inter-corporate dividends, which are generally tax-free between connected Canadian corporations.

Owners use a holdco for several reasons at once. It moves retained earnings away from the operational risk and creditors of the active business, which is a form of creditor protection. It provides a separate place to hold passive investments. And it positions the group for a future sale, because a buyer typically wants a clean operating company without years of accumulated investments inside it — which can also help the operating-company shares qualify for the lifetime capital gains exemption.

The trade-offs are the extra compliance cost of a second corporation and the passive-investment-income rules, which can reduce access to the small-business deduction where passive income across the associated group climbs above defined thresholds. Whether a holdco fits depends on the size of the surplus, the risk profile of the business, and the plan for eventual sale or succession.

Most incorporations, sales, and reorganizations have tax consequences worth more than the legal fees. A tax-aware lawyer drafts the share structure, the rollover, and the agreement with the after-tax outcome in mind — not just the corporate-law mechanics.

Yes — most corporate engagements involve close coordination with the client's accountant for valuation, rollovers, T2057 filings, and post-closing compliance. We treat your accountant as part of the team.

Most matters — incorporations, shareholder agreements, share sales, simple reorganizations — are quoted on a fixed-fee basis after we understand scope. Complex transactions and litigation are typically billed hourly with a budget cap. We will beat any competing Canadian tax-lawyer quote by 20%.

It depends on the province and on the class of shares. Provincial Colleges of Pharmacists regulate who may own and control a pharmacy. In most provinces, only licensed pharmacists may hold the voting shares of a pharmacy corporation, while non-pharmacist family members (a spouse, children, or a family trust) may hold non-voting shares. A will that leaves voting shares to a non-pharmacist can lead the College to refuse registration or suspend the Certificate of Accreditation until control is restored to a licensed pharmacist.

Quebec is stricter — only licensed pharmacists may own a pharmacy, and ownership must be direct rather than through a holding company, trust, or family members. Where no pharmacist heir exists, the usual approach is to authorize the executor to sell the shares to a qualified pharmacist purchaser. Confirm your province's rules before structuring your will.

In an asset sale, the buyer acquires individual assets — inventory, fixtures, and goodwill — rather than the corporation. The proceeds are generally treated as business income and recapture at the corporate level, the vendor cannot use the Lifetime Capital Gains Exemption (LCGE) on goodwill held in the corporation, and each licence, contract, and permit must be transferred individually.

In a share sale, the buyer acquires the shares of the Pharmacy Professional Corporation. If the corporation qualifies as a Qualified Small Business Corporation (QSBC), the vendor can claim the LCGE on the capital gain, and there is no need to re-register licences or contracts. A share sale generally produces a better after-tax result for the seller, which is why many pharmacists structure the corporation so a share sale is feasible. The right choice depends on the corporation's liabilities, its QSBC status, and the buyer's preferences.

To claim the Lifetime Capital Gains Exemption, a pharmacy corporation generally needs at least 90% of its assets used in an active business at the time of sale or death. If a life-insurance policy's cash surrender value is recorded as a passive investment inside the operating Pharmacy Professional Corporation, it can count as a non-active asset and jeopardize that QSBC status.

Holding the policy in a Holding Company instead keeps the operating corporation's assets "pure," lets the Holdco accumulate the cash value and invest surplus dividends, and segregates the insurance proceeds for family use or buy-sell obligations. On death, the death benefit (less the policy's adjusted cost basis) creates a Capital Dividend Account credit in the Holdco, allowing tax-free capital dividends to the estate or shareholders.

Purification is the process of removing or restructuring passive and investment assets — excess cash, marketable securities, non-business real estate — so that a corporation meets the Qualified Small Business Corporation (QSBC) tests and the shares qualify for the Lifetime Capital Gains Exemption. Common techniques include transferring excess cash and investments to a Holding Company, paying dividends or bonuses to reduce retained earnings, selling non-operating assets, and moving corporate-owned insurance to a Holdco.

Because two of the three QSBC tests look back over the 24 months before a sale or death, purification should begin at least 24 months ahead. Purification crammed into the final weeks before closing invites the CRA to treat it as part of the disposition and to challenge the holding-period test, so the earlier the corporation is cleaned up, the safer the exemption claim.

When a pharmacist dies owning corporation shares, the same value can be taxed twice: once as a capital gain on the deemed disposition of the shares at death, and again as a dividend when the corporation's retained earnings are later distributed to the estate or heirs.

A pipeline plan addresses the second layer. The estate incorporates a new corporation, transfers the deceased's shares to it under a section 85 rollover in exchange for a promissory note equal to fair-market value, then amalgamates or winds up the original corporation into the new one. Over time the new corporation repays the note from the retained earnings as a capital repayment rather than a taxable dividend. The CRA generally expects a reasonable delay (often around 12 months) before repayment to confirm the reorganization is bona fide. The result is that only the capital gain at death is taxed. An alternative, the subsection 164(6) loss carry-back, suits estates where the corporation will be wound up shortly after death.

Under section 167 of the Excise Tax Act, the sale of an entire business as a going concern can be relieved of GST/HST where both the buyer and the seller are registrants and the buyer continues to operate the business immediately. The election is made jointly on the prescribed CRA form and should be referenced in the purchase-and-sale agreement.

For a pharmacy sale, the election can remove a significant amount of tax from the transaction. It is worth confirming registrant status on both sides and including the election in the definitive agreement so it is not overlooked at closing.

The consequences can be severe. Every pharmacy must have a licensed pharmacist acting as Designated Manager, and at death the executor must promptly appoint a replacement and notify the provincial College within the deadline (often 30 days). If no licensed pharmacist is in place, the College can require the pharmacy to close, prescriptions transfer elsewhere, and goodwill erodes quickly.

On the tax side, the deemed disposition of the corporation's shares at death can trigger a large capital-gains liability, and if the corporation is not a Qualified Small Business Corporation on the date of death, the Lifetime Capital Gains Exemption may be lost. A will that grants the executor authority to operate the pharmacy, appoint a Designated Manager, and carry out post-mortem reorganizations — combined with advance purification and, where appropriate, an estate freeze and a family trust — preserves both the business value and continuity of patient care.

The choice has significant tax consequences and the buyer and seller usually have opposing preferences. Sellers often prefer a share sale, because it can access the Lifetime Capital Gains Exemption on qualifying shares and generally produces a single layer of capital-gains tax. Buyers often prefer an asset sale, because it lets them step up the cost of depreciable assets and avoid inheriting the company's historical liabilities.

An asset sale inside a corporation can create two layers of tax — at the corporate level on the sale and again when proceeds are distributed to shareholders — though planning can mitigate this. The right structure depends on the company's assets, its share status, the parties' relative bargaining power, and the timeline.

Because the structure drives the after-tax outcome, it is worth modelling both options early in negotiations rather than after a deal is signed. Planning before the sale preserves the most options.

The general rule of thumb is that once your business generates $30,000 or more in a year, you are required to charge and collect GST/HST. Many owners cross that threshold without realizing it and later learn — often during an audit — that they owe the tax even though they never collected it from their customers, which can be a costly surprise.

The correct rate depends on where your customer is and where the goods or services are supplied, not where you are: for example, a Toronto business charges 13% HST to an Ontario customer, 5% GST to an Alberta customer, and 0% to a customer outside Canada. Once you register, you can also claim input tax credits for the HST you pay on your own business expenses, which reduces the net amount you remit. The safest practice is to register for an HST number and apply the correct tax to every transaction.

Sellers usually prefer a share sale (Lifetime Capital Gains Exemption can shelter up to ~$1M+ of gain on Qualified Small Business Corporation shares). Buyers usually prefer asset sales (step-up in basis, lower successor-liability risk). The price negotiation is partly about who absorbs the tax differential.

An indexed exemption for capital gains on Qualified Small Business Corporation shares (and qualified farm/fishing property). Multiplying it across family members through estate freezes and family trusts is one of the highest-leverage tax-planning moves available to Canadian business owners.

Yes. Most cases qualify for a free, no-obligation consultation with one of our tax lawyers. During the call we'll review your situation, explain your options, and give you a clear quote if you decide to retain us.

Yes. Barrett Tax Law represents clients across Canada. We have offices and local phone lines in Toronto, Calgary, Edmonton, Fort McMurray, Ottawa, Vancouver, and Winnipeg, plus a national toll-free line at 1-877-882-9829.

Barrett Tax Law is a Canadian boutique tax law firm that represents individuals and businesses in their dealings with the Canada Revenue Agency. The firm's work spans CRA audits and disputes, voluntary disclosures, Tax Court of Canada litigation, collections matters, and corporate and estate tax planning.

The firm was founded in 2009 and has represented many thousands of clients across Canada. Its head office is in Concord, Ontario (Vaughan), and it serves clients nationwide. You can reach the firm toll-free at 1-877-882-9829 (1-877-8-TAXTAX).

Most matters qualify for a free, no-obligation consultation, and most are quoted on a fixed-fee basis once scope is understood, so the cost is known before work begins.

Accountants prepare returns and financial statements. Tax lawyers represent you when those returns are challenged, audited, or prosecuted — and our communications are protected by solicitor–client privilege, which accountant communications generally are not.

Most CRA disputes are civil. Criminal prosecution is reserved for serious tax evasion or fraud, usually involving deliberate misrepresentation. If you have unreported income, a voluntary disclosure is one of the standard ways to reduce criminal-prosecution risk.

We typically begin work within 24 hours of being retained. For audit deadlines, Notices of Objection, and other time-sensitive matters, we move immediately.

We routinely handle 5+ years of unfiled returns. Through the Voluntary Disclosures Program — applied for before the CRA contacts you — we can usually eliminate gross-negligence penalties and limit interest exposure.