At Siegal Tax Law we restrict our practice to doing one thing – resolving tax disputes - and doing it well. We have extensive experience efficiently and pragmatically resolving disputes at all stages:
Litigation – Tax Court
We have a proven track record of success (over 50 wins) conducting trials in the Tax Court of Canada on a wide range of matters such as tax treaty interpretation, employee/contractor status, and interest expense deductibility.
We assist our clients in the handling of CRA audits. We typically advise on audit query response strategies, assist in the drafting of client submissions, and prepare clients for CRA interviews. When necessary we, as counsel, make direct submissions to CRA officials on audit matters.
Litigation – Federal Court
We successfully handle judicial review applications in the Federal Court on matters challenging the Canada Revenue Agency's use of its discretionary powers.
Transfer Pricing Resolutions
We prepare submissions to, and represent clients before, the Canadian competent authority to reduce double taxation and obtain advance pricing agreements. We have extensive experience assisting with transfer pricing audits, appeals and litigation.
Litigation – Appellate Courts
We have successfully represented our clients before the Federal Court of Appeal and the Ontario Court of Appeal. We provide appellate litigation services for all matters regardless of whether we were counsel at the first instance.
We take on the internal counsel function, as part of our In-House Advisory services, to assist with the management of external litigation for both tax and non-tax disputes. Typical duties include quarterbacking internal document production, liaising with external employees, board briefings, selecting witnesses, managing litigation budgets, and reviewing the strategy of outside counsel.
We have a track of record of success for resolving tax disputes at the administrative level without the need for litigation. We have successfully resolved a wide variety of issues including SR&ED claims and transfer pricing disputes working with CRA officials both locally and at Headquarters in Ottawa.