Tax Litigation

Our tax litigation group has extensive experience in resolving disputes between taxpayers and Canada Revenue Agency.

What is your tax problem?  We can provide help in many areas, including problems relating to: 

  • Unfiled tax returns
  • Unpaid taxes
  • Unreported income
  • Unpaid source deductions (e.g. payroll, Canada Pension Plan, Employment Insurance, Goods and Services Tax)
  • Tax liability as a director of a company
  • Audits
  • Appeal/objection to a tax assessment
  • Criminal investigation
  • Criminal charges under s. 238 of the Income Tax Act (Canada) for failing to keep proper books and records or failing to file returns
  • Criminal charges under s. 239 of the Income Tax Act (Canada) for failing to report income 

We also know how to properly respond to requests from Canada Revenue Agency, such as, “Requirements for Information” and “Requirements to Produce Documents,” and can assist you in responding to demands for payment of unpaid taxes. 

In addition to dispute resolution with Canada Revenue Agency directly (during the audit and appeal process), our team has represented taxpayers before the National Rectification Committee, the Saskatchewan Court of Queen’s Bench, the Saskatchewan Provincial Court, the Tax Court of Canada and the Federal Courts of Canada. 

We feel that our successes outside of court are also important.  Our experience has enabled us to resolve the majority of our cases quickly and efficiently without the need for formal court proceedings. This may be achieved through the internal appeal process with Canada Revenue Agency or through negotiations with counsel at the Department of Justice. In addition, we have successfully obtained a number of rectification orders to “undo” third party mistakes that resulted in unintended tax consequences to our clients.

© 2018 Stevenson Hood Thornton Beaubier LLP