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Drache Aptowitzer LLP

Drache Aptowitzer LLP has represented clients in tax disputes to the CRA, at the Tax Court of Canada, the Federal Court of Appeal and at the Supreme Court of Canada. Our clients include Canadians and foreigners, for profit, and not for profit corporations in dispute with the CRA. For our work we were recognized as one of the Top 10 tax law boutique firms in Canada by Canadian Lawyer magazine.



The tax experts at Drache Aptowitzer LLP have significant expertise helping individuals and corporations resolve disputes with the Canada Revenue Agency over tax owing.

Voluntary Disclosure

The Voluntary Disclosure Program of the CRA allows those who have made mistakes in prior tax returns to advise the CRA and fix their mistakes without penalties.

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Unfiled Returns

Many Canadians fall behind in filing their yearly income tax returns. Many times this lapse is noticed by the CRA, who makes a formal request for the filings.

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Tax disputes generally begin with an audit by a CRA Officer. These officers typically demand all of your books and records, and an opportunity to speak with and question you about..

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HST Disputes

HST disputes often begin in ways that are similar to income tax disputes. Indeed, many HST disputes are related to income tax audits. HST is an extremely complicated Act and it is...

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If a taxpayer disagrees with an Auditor's position an individual or corporation may file an objection with an Appeals officer. Generally, an Appeals Officer is more experienced.

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Tax Court

If a dispute is not resolved at the audit or objection stage, the matter will appear before the Tax Court. There are two (2) types of procedures within the Tax Court.

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Below are some of the cases we have been successful in resolving. This is a sampling of the types of cases we
have handled in the past. If you do not find an example of your situation below, feel free to contact us at
info@dracheaptowitzer.ca with any questions you may have.


Our client retained us after being assessed a penalty of almost $550,000. We handled the matter from the Tax Court, through the Federal Court of Appeal and to the Supreme Court of Canada.

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Our client retained us after she was assessed capital gains tax on the sale of five homes in six years.After filing a Notice of Objection we showed that each of these sales was, in fact,..

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After several attempts by a variety of different charities, we obtained a stay for the revocation of a charity, at the time the first charity to do so.

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Drache Aptowitzer LLP was named one of the Top Ten Tax Boutiques in Canada by Canadian Lawyer magazine for 2019 – 2020. Our tax practice centers on resolving disputes with the CRA before they happen, an after the CRA raises an issue. If you need to understand the CRA’s position on a given issue or resolve a dispute with the CRA (i.e. they are seeking more tax from you then you think you owe) we can help you.

Tax litigation and the application of the law to charities and not for profits
Charity & non-profit, corporate, and tax law


recordings, interviews

Compelling Oral Interviews Without Recording Is a Recipe for a Disaster

We have written previously about the difficulties that arise when CRA conducts oral interviews of taxpayers. While there is clear authority to do so, and indeed merit in having a conversation to explain the nature of a business, all interviews are fraught with danger. This can be as a result ...
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It’s Giving Season: Tax Credits for Charitable Donations vs. Political Contributions

By: Alexandra Tzannidakis In the public mind, the idea of tax credits for giving to ‘good causes’ sometimes leads to confusion and conflation of charitable tax credits and political tax credits. The truth is that charities and political causes are legally very distinct concepts (there is no such thing as ...
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The Penny Drops

It is common knowledge that taxation authorities around the world are playing catch up with the developments of new technology. One of the most interesting areas of such ongoing technological development has been the advent of Bitcoin. But at least in the case of Bitcoin it seems that the Income ...
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