Fasken Martineau has a leading practice in tax dispute resolution, advocacy and litigation. Our lawyers routinely advise clients on all stages of the dispute resolution process from the audit to administrative appeal to tax litigation. Our team effectively and aggressively advocates for our clients from the outset with the goal of a satisfactory resolution of the matter .

We have experience representing Canadian and foreign clients at all levels within the Canada Revenue Agency (CRA) and other provincial and international tax authorities in controversies involving domestic and international tax (including transfer pricing disputes). Our tax team has litigated cases before a wide range of courts and tribunals, including the Tax Court of Canada, the Federal Court of Appeal, the Supreme Court of Canada and various provincial courts.

Our Clients

Our clients include domestic and international businesses including manufacturers, financial institutions, and natural resource companies. We also act for individuals and private trusts with respect to personal and individual income tax matters.

Our Expertise

  • Assess tax risks in specific transactions including the potential application of general anti-avoidance rules (GAAR)
  • Advice on obtaining advance tax rulings, clearances, technical interpretations and comfort letters
  • Advice on proceedings relating to tax covenants and other means sharing tax risk
  • The international/cross border enforcement of tax liabilities
  • Assistance with reputation management in relation to tax
  • Advice on the tax implications of a wide range of commercial disputes, including in the context of labour/employment litigation
  • Management of complex tax audits including Scientific Research and Experimental Development (SR&ED), GAAR, transfer pricing, and Value-added Tax/Goods and Services Tax (VAT/GST)
  • Preparing and filing voluntary disclosure applications
  • Preparing and filing notices of objection at the administrative appeals stage of the tax dispute
  • Providing advice at the audit stage regarding the proper conduct of an audit by the taxation authorities
  • Responding to collections actions by taxation authorities
  • Challenging actions and decisions of the taxation authorities, and other government authorities, through the judicial review process
  • Representation before all levels of court and administrative