Content provided by John Sorensen, associate, Gowlings LLP
All legal disputes have the potential to be complex but tax disputes can be further complicated by rigid procedures.
The various stages of a typical tax dispute are as follows:
- 30 Day Letter
- Notice of Reassessment
- Notice of Objection
- Assessment / Reassessment
- Appeal to the Tax Court of Canada
- Further appeals to the Federal Court of Appeal and the Supreme Court of Canada
For an overview of each of these stages, please view a copy of the Policies, Penalties and Tax Dispute Resolution presentation made by John to the Ontario Bar Association Tax Section in 2013, located under the Forms page.
There are a variety of possible ways to resolve tax disputes other than a court process and may include:
- Voluntary disclosures to the Canada Revenue Agency
- Fairness or taxpayer relief applications
- Rectification applications
- Remission order applications
- Judicial review applications
For additional information regarding the voluntary disclosure process, please see a copy of John’s presentation to the Canadian Tax Foundation – Voluntary Disclosure and Taxpayer Relief.