Assistance to Accountants (call, no obligation)
Audit Advice
Income Tax Defense (Ten Years Tax Prosecution Experience)
Fail to File, Evasion, Search Warrant Responses and Advice
Assessment Appeals, Notices of Objection and Extension Applications
Fairness Applications, Amnesty and Voluntary Disclosure Applications
Contesting Spouse Transfer Assessments and GAAR Assessments
Net Worth Assessment Objections and Appeals
Appeals – Notices of Objection, Administrative Reviews and Assessment Appeals to the CRA or Tax Court of Canada (TCC) regarding Income Tax, GST, or CPP and EI assessments or decisions
Audits – Advice covered by solicitor-client privilege (get it early, especially if it could be bad). Your communications with an accountant discussing your tax problems are not privileged and if CRA decided to proceed criminally, they can seize such records under a search warrant and such records could also be disclosed on the audit thereby leading to criminal investigation if the records were not carefully framed. By retaining counsel and having the counsel retain the accountant to assist, the accountant’s new records and analysis and communications which are to assist in the provision of legal advice, if kept in a separate file, can be protected by solicitor client privilege.
Extensions – applications to the CRA or to the TCC regarding missed deadlines – Note: These have deadlines too!
Relief – Fairness applications for waiver of penalties and interest
Amnesty – Voluntary Disclosure Applications (coming forward before the CRA catches you)
Defense – Fail to Fail, Evasion, Failure to Comply with Requirements to Provide (These are criminal prosecutions we defend or resolve. David prosecuted tax for ten years. Even in a seemingly hopeless case, the investigator may make many mistakes or may have breached your charter or other rights)
Assistance to Accountants (call, no obligation) – Acting as Counsel and Engaging Accountant to Assist Counsel to Ensure Solicitor-Client Privilege Protection of Accountant Further Work Product File from CRA in Subsequent Civil or Criminal Matters
Contesting Net Worth Assessments (and planning advice)
Contesting Spouse Transfer Assessments and GAAR Assessments
Challenging Seizures (by execution or by search warrant), Excessive Seizure Response, Motions to Supress Documents (and hard drives seized), In Camera and Ex Parte Applications to Protect Document Privacy