Tax Litigation

The firm’s tax litigation practice covers all aspects of tax dispute resolution including complex audits, administrative appeals, competent authority (MAP) and judicial proceedings before federal and provincial courts in Canada.

Our tax litigation team’s expertise is recognized in all areas of tax dispute resolution, with a particular emphasis on transfer pricing, tax incentives (SR&ED, e-business and resources tax credits), rectification, commodity taxes, voluntary disclosures, information requirements and other audit measures. We regularly act for clients before provincial and federal courts at the trial and appellate levels, as well as at the competent authority level under mutual agreement procedures (MAP) and advance pricing arrangements (APA).

Because of its extensive and wide experience, our team can offer practical and innovative solutions that help protect your business interests and efficiently resolve your tax disputes.

Transfer Pricing

The firm is recognized as one of Canada’s leading law firms in transfer pricing, both at the advisory and dispute resolution level.  We assist multinational enterprises in all facets of their Canadian tax liability, from advising on transactions, to making quarterly provisions for Fin 48 and other reporting purposes, to defending positions at any level from audit, through the administrative appeals level, to competent authority proceedings and, as needed and as a last resort, before the courts.

Our lawyers regularly assist the firm’s clients in managing transfer pricing risks associated with ongoing operations, business restructurings (e.g., mergers, acquisitions and divestitures) and special transactions (e.g.,  migration or licensing of intellectual and other property).  This includes implementing best practices in the preparation of transfer pricing documentation to optimize compliance and minimize the risk of adjustments and penalties.

We also represent taxpayers seeking to apply for mutual agreement procedures (MAP), advance pricing arrangements (APA) and accelerated competent authority procedures (ACAP).  Our lawyers work collaboratively with our clients’ finance, tax and legal teams as well as their external advisors to provide effective solutions to their transfer pricing challenges and protect privileged exchanges.

 

Tax Planning

The firm offers an extensive array of tax planning services including for the structure of domestic and cross-border transactions, sales and commodity tax optimization, corporate reorganizations (mergers, acquisitions or divestitures), financing transactions, the purchase and sale of a business, immigration, trusts and charitable organizations.

Our priority is to develop sound tax planning that minimizes audit and litigation risk. This firm’s extensive experience in tax audits and litigation allows us to better evaluate such risks and to develop solutions suited to your specific needs.