We are a super-boutique Canadian tax and trade law firm, with litigation and planning expertise in tax, trade, GST/HST and customs matters. Our client base is comprised of national and international leaders in almost every industry sector who have come to rely on us for the specific and cost-effective litigation services and advice that we can provide.
When matters cannot be resolved with the governmental authorities to our clients’ satisfaction, we represent them in tax and trade litigation before all relevant courts, and at all levels of court, including before the Tax Court of Canada, the Canadian International Trade Tribunal, the Federal Court and Federal Court of Appeal, and the Supreme Court of Canada.
Our tax practice includes a focus on Canada’s GST/HST system, which is a multi-level, value-added taxing system, imposed under Canada's Excise Tax Act (the ETA), and administered by the Canada Revenue Agency (the CRA). The GST applies at a 5% rate federally, and the HST applies an additional provincial component by province, resulting in GST/HST rates ranging from 5% to 15% nationally.
Our Customs and Trade practice focuses on all Canadian issues affecting the movement of goods to and from Canada, including tariff classification, origin, valuation, marking, seizures and ascertained forfeitures, and export controls. Our trade practice also includes assisting clients on NAFTA, and Anti-Dumping & Countervail (SIMA) matters, and much much more.
Our firm has a special focus on direct selling companies. Our firm is truly a “one stop shop” for direct sellers looking to expand into the Canadian marketplace. From tax structuring assistance to help with incorporation, to compliance with Canada’s anti-pyramid laws and provincial consumer protection licensing, we have assisted hundreds of direct selling companies in the Canadian marketplace with their legal compliance, including four of the last six DSA Rising Star Award winners!
NOT ALL CRA DISCRETIONARY DECISIONS GO TO FEDERAL COURT!
Since the Supreme Court of Canada’s 2024 decisions in Iris Technologies and Dow Chemical, many taxpayers and tax practitioners have become well aware that the Tax Court of Canada is not a ”one-stop shop” for tax disputes.
The rule of thumb for "jurisdiction" is that most tax cases go to the Tax Court of Canada, but that CRA discretionary decisions must be challenged in the Federal Court.
As we see in the Ingredion case dealt with below, that may not ALWAYS be the case – and it introduced a third possible jurisdiction in some cases: Provincial Superior Courts!
POST COVID, CRA APPEALS BRANCH SLAMMED WITH NEW WORK!
The Canada Revenue Agency (CRA) recently released its 2025-26 Departmental Plan (“the Report”), outlining its priorities and recent performance. It reveals a critical piece of information that should serve as a warning for all taxpayers: the CRA is being overwhelmed by Notices of Objections (“NoOs”) and is struggling to keep up.
As we report on below, large businesses with complex tax issues are likely to suffer the most.
CRA DATA SHOWS THE MAJORITY OF TAX AUDITS OVERTURNED!
When most taxpayers receive a Notice of Assessment from the Canada Revenue Agency (CRA), they likely have the following concern: what did I do wrong? That first instinct – although likely well-founded in the human psyche – ends up being a statistically incorrect assumption. In fact, the most recent data from the CRA suggests that the majority of CRA Assessments are INCORRECT and are ultimately overturned on Objection.
This Tax Audits Series Report reflects on this data and its implications and “best practices” for taxpayers.
Tax professionals are well aware of how critical it is to file Notices of Objection on time — generally within 90 days of the mailing of a Notice of Assessment. For professionals and taxpayers who find themselves unable to have met this deadline, section 303 of the Excise Tax Act (the “ETA”) (and section 166.1 of the Income Tax Act) provides some potential relief (i.e., an extension to file, provided certain preconditions are met).
A recent Tax Court of Canada (“TCC”) decision inLamarnic & J Ltd. v. The Queen (2022 TCC 35) explores this rule but, at the same time, serves as a cautionary tale for taxpayers and tax professionals alike that these extension rules may only be available if the rules are strictly adhered to within set statutory timelines.
Last March 18th, the CRA announced the suspension of the vast majority of audit activities as a result of the COVID-19 pandemic. How quickly things change!
