At Miller Thomson, our Tax Controversy and Disputes Resolution Group intervenes early on matters of taxation, partnering with clients to minimize the risk of objection or reassessment and avoid tax litigation altogether.
When matters escalate, our formidable team fights your corner in interactions with tax authorities, calling on its considerable expertise in negotiating settlements and litigating tax matters. In every case, we are dedicated to resolving tax disputes swiftly and efficiently so that you can stay focused on your core business.
Leverage Our Experience and Expertise to Gain the Upper Hand
Thinking like the opposition comes naturally to Miller Thomson’s Tax Controversy and Disputes Resolution lawyers, since many of them are former litigators for provincial and federal tax agencies, where they gained unique insights regarding the motivations of tax authorities.
The proactive and creative professionals in our team leverage their extensive past experience to clients’ advantage, combining their knowledge of national and international tax enforcement trends to anticipate and prevent future tax disputes before they can arise.
Our group consists of experienced individuals who are also skilled at negotiating with tax authorities and in conducting appeals before the various tax and appellant courts. Our clients, both individuals and corporations, receive measured guidance and strong representation in reaching resolutions.
Nationwide Coverage, Firm-wide Integration
With offices in Ontario, Québec, British Columbia, Alberta, and Saskatchewan, Miller Thomson is well-positioned to assist taxpayers anywhere in Canada.
From audits and objections before the Canada Revenue Agency, Revenu Québec and other provincial authorities to matters before the courts, our team is here to assist you throughout the entire tax process.
Our Tax Controversy and Disputes Resolution lawyers also work closely with our broader Tax Group to ensure we offer full service for all of our clients’ tax issues. We provide innovative advice and skilled litigation services when our clients are faced with tax-related problems and obstacles. Since tax disputes can be civil and criminal in nature, we have proven expertise in these areas of law.
We also offer customs and international trade services to address a range of issues, including tariff classification, origin determination, duty relief, regulatory compliance, and assistance with audits, seizures, and penalties.
Comprehensive Legal Support
We assist clients with a wide range of tax controversy and disputes resolution services, including:
- Negotiations with government tax auditors and appeals officers
- Disputes involving Income Tax, GST, and withholding tax
- Voluntary disclosure applications
- Disputes concerning taxation of commercial transactions or agreements
- Disputes regarding taxation of particular industries
- Rectification and Rescission matters
- Customs disputes
- Appearances before the Canadian International Trade Tribunal, the Tax Court of Canada, the Federal Court, the Federal Court of Appeal, and applications to the Supreme Court of Canada
- Tax matters before the criminal courts
Notable matters
Our success rate in court matters remains unsurpassed. Listed below is a representative sample of the different types of tax litigation matters that we have won on behalf of our clients:
- Income Tax Litigation ranging from business expenses to transfer pricing cases.
- Provincial Tax matters covering Retail Sales Tax challenges to Employer Health Tax Issues.
- Rectification matters.
- Recission issues.
- Appeals, covering both judicial issues, appeals and leave applications to the Supreme Court of Canada, as well as Supreme Court cases.
- Criminal Tax matters, involving investigations, Charter challenges, jury and non-jury trials.
