Tax disputes begin when the CRA effectively believes that an individual or corporation owes more tax then taxpayer has claimed they are owing. (In some circumstances, this relates to the CRA believing there is a smaller loss than the taxpayers has claimed). There are several opportunities to resolve these disputes, they begin at the audit stage, progress through the appeals stages and the Tax Court. If the dispute is not resolved at any of these opportunities the matter may end up before the Federal Court of Appeal.
We have appeared at the Federal Court of Appeal several times to argue matters contained in the Income Tax Act. Drache Aptowitzer LLP lawyers are amongst the most experienced in the country in appearing before this Court. Indeed, Mr. Aptowitzer is also a member of the Canadian Bar Association’s Federal Courts Bench and Bar Committee.
We would be happy to discuss appealing your issue to the Tax Court of Canada and the parameters for doing so.