Calgary Tax Lawyer

Calgary and Alberta tax matters

CRA audits, objections, Tax Court of Canada appeals, and voluntary disclosures are federal, so we represent Calgary clients on these matters by phone, by video, and in person on request. We do not operate a staffed walk-in office in Calgary; meetings are arranged when a file calls for one.

Local CRA offices and courts

The CRA Calgary Tax Services Office handles much of southern Alberta's personal and business audit and objection work, and the Tax Court of Canada holds regular sittings in Calgary, so a Calgary appeal does not require travel to another province for the hearing. The Federal Court of Canada also sits in Calgary for judicial review of CRA decisions. As everywhere, the 90-day objection deadline after a reassessment and the one-year extension window are hard limits — the most common reason a strong dispute is lost is a missed date rather than a weak position.

Alberta tax considerations

Alberta's tax environment is different from Ontario's in ways that matter to planning. Alberta has the lowest general corporate tax rate among the provinces and no provincial sales tax, which changes the arithmetic on corporate reorganizations, dividend-versus-salary decisions, and where to situate a holding company. Alberta corporate documentation runs under the Alberta Business Corporations Act (ABCA) rather than the OBCA, and there is no Alberta equivalent to Ontario's Employer Health Tax or Land Transfer Tax. Provincial residency on December 31 still determines which province's rates and credits apply, which can be a live issue for people who split time between Alberta and another province.

Common Calgary issues we see

Calgary's energy-driven economy produces a recognizable cluster of matters. Oil-and-gas income and consulting arrangements draw reassessments over the timing and characterization of income, and incorporated consultants in the energy sector face Personal Services Business (PSB) classification risk when they work full-time for a single payer. Real estate professionals operating through Personal Real Estate Corporations (PRECs), physicians and dentists with professional corporations, and owner-managed businesses facing CRA collections are all common. Where prior-year income or foreign-asset reporting (T1135) was incomplete, the Voluntary Disclosures Program may be available, subject to careful eligibility review.

Personal Services Business risk in the energy sector

The PSB issue deserves its own note because it is so common among Calgary consultants. When an incorporated worker provides services that, but for the corporation, would make them an employee of the payer — working set hours, under direction, without their own business risk — the CRA can treat the corporation as carrying on a personal services business. The consequences are severe: the small-business deduction is denied, the general corporate rate plus an additional PSB tax applies, and most ordinary corporate expenses are disallowed. We review the substance of the engagement (control, ownership of tools, chance of profit, integration) and, where the structure is exposed, advise on contract terms and operating practices that better reflect a genuine independent business.

How the CRA dispute process runs

A Calgary file generally moves from audit query to proposal letter to reassessment, then to a notice of objection filed with the CRA Appeals branch within 90 days. A late objection can sometimes be revived through a one-year extension application on recognized grounds. If Appeals confirms the assessment, the appeal goes to the Tax Court of Canada, which sits in Calgary under either its informal or general procedure depending on the amounts in dispute. Collections action — requirements to pay, bank-account holds, liens — can run in parallel, so we often pursue a collections-hold strategy at the same time as the underlying dispute.

How we work with Calgary clients

A typical file begins with a confidential consultation by phone or video. We review the CRA letters, identify the deadlines, explain the options, and set scope and fees in writing. We coordinate with your existing Calgary accountant where you have one, and we represent clients through a Tax Court of Canada hearing in Calgary when a matter proceeds to litigation.