Miller Thomson’s Tax & Customs Dispute Resolution lawyers are dedicated to finding solutions for our client’s provincial, federal or international tax litigation challenges. We have recognized expertise in negotiating tax disputes and in litigating tax matters.
Many of our lawyers in the Tax & Customs Dispute Resolution group were former litigators for provincial and federal tax authorities. Our group consists of experienced individuals skilled at negotiating with tax authorities and in conducting appeals before the various tax and appellant courts. Our clients, both individuals and corporations, receive measured guidance and strong representation in reaching resolutions.
We are here to assist you throughout the complete process from audits and objections, before Revenu Québec, other provincial authorities, or the Canada Revenue Agency, to matters before all courts.
Our Tax Litigation & Dispute Resolution lawyers work closely with our broader Tax Group to ensure we offer full service for all of our clients’ tax issues. We provide innovative advice and skilled litigation services when our clients are faced with tax-related problems and obstacles.
Since tax and customs disputes can be civil and criminal in nature, we have proven expertise in these areas of law.
We also offer customs and international trade services to address a range of issues, including tariff classification, origin determination, duty relief, regulatory compliance, and assistance with audits, seizures, and penalties.
Significant Areas of Service:
- Negotiations with government tax auditors and appeals officers
- Disputes involving Income Tax, GST, and withholding tax
- Voluntary disclosure applications
- Disputes concerning taxation of commercial transactions or agreements
- Disputes regarding taxation of particular industries
- Rectification and Rescission matters
- Customs disputes
- Appearances before the Canadian International Trade Tribunal, the Tax Court of Canada, the Federal Court, the Federal Court of Appeal, and applications to the Supreme Court of Canada
- Tax matters before the criminal courts
Our success rate in court matters remains unsurpassed. Listed below is a representative sample of the different types of tax litigation matters that we have won on behalf of our clients:
- Income Tax Litigation ranging from business expenses to transfer pricing cases.
- Provincial Tax matters covering Retail Sales Tax challenges to Employer Health Tax Issues.
- Rectification matters.
- Recission issues.
- Appeals, covering both judicial issues, appeals and leave applications to the Supreme Court of Canada, as well as Supreme Court cases.
- Criminal Tax matters, involving investigations, Charter challenges, jury and non-jury trials.
Miller Thomson to release comprehensive Federal Budget review on March 22
Our in-depth analysis of the Federal Budget will be released later this week. Corporate tax lawyers Ron Choudhury and Rahul Sharma, and Social Impact lawyer Nicole D’Aoust will be at budget lock-up in Ottawa on March 22 to bring you the latest tax measures...
Miller Thomson wins M&A Awards
Miller Thomson LLP was recently named the winner of the ACQ Global Award 2014 for Tax Litigation Law Firm of the Year- Canada and the Transfer Pricing Law Firm of the Year- Canada. A leading global M&A magazine, ACQ polled...
David Chodikoff’s Tax Litigation book now available from Thomson Reuters
Congratulations to David Chodikoff on the release of his book, Tax Litigation. This is David’s fifth published work. He is the general editor of the book and co-author of the Canadian chapter along with corporate and commercial associate Laura Etherington. Tax Litigation is...
David Chodikoff’s Tax Litigation book to be launched at the International Bar Association Conference in October
Miller Thomson congratulates David Chodikoff on the upcoming October release of his book Tax Litigation. This is David’s fifth published work. He is the general editor of the book and co-author of the Canadian chapter along with corporate and commercial associate...
David Chodikoff interviewed by CBC on offshore tax evasion
David Chodikoff was interviewed by CBC’s The National for a story on offshore tax evasion that aired on Wednesday, June 12. David’s interview was part of a CBC News report on their findings that the government overstated its offshore tax-evasion...
David W. Chodikoff selected as one of the leading tax controversy advisors in the world
David W. Chodikoff has been selected as one of the leading tax controversy advisors in the world and will be included in the International Tax Review’s Tax Controversy Leaders Guide of 2013
Miller Thomson Saskatoon is pleased to announce that Mr. Lyle Bouvier has joined the firm as a partner. Lyle brings with him 14 years of experience in tax litigation with the Department of Justice.
Lyle has argued cases in all levels of court and has extensive experience in the Tax Court of Canada, Federal Court Trial Division and Federal Court of Appeal.
Sheldon Silver named a top tax litigator in Canada by Chambers Global.
Mr. Silver, a member of Miller Thomson’s Corporate Tax and Tax Litigation and Dispute Resolution groups, was named a “Senior Statesman” in the Chambers Global 2011 report on Canada’s top tax litigators. In this March 24th article in the Globe and...
David Chodikoff speaks at the OBA Taxation Law Program
David Chodikoff will be speaking at the OBA’s “From Formal Treaty Requests to Data Leaks: Identifying and Discussing International Tax Avoidance and Evasion”.
David Chodikoff speaks on Essential Tax Updates
David Chodikoff is presenting on “Essential Tax Updates: Dividend Traps, Small Business Deductions, Rectification and Privilege” at the 2017 OBA Institute.
David Chodikoff speaks on Driving a culture of legal and ethics compliance at the 15th General Counsel’s Role in Maximizing Board Effectiveness Course.
Bill Fowlis presents to the Rotary Club of Calgary on “Tax Planning with respect to the Ownership of US Real Property by Canadians”
Bill Fowlis instructs a course for the Institute of Chartered Accountants of Alberta in Calgary Entitled, “Taxation of Family Trusts – Advanced”
Bill Fowlis instructs a course for the Institute of Chartered Accountants of Alberta in Calgary Entitled, “Taxation of Family Trusts – Basic”
Shashi B. Malik speaks on “Planning for the Tax Efficient Sale of Business” at a luncheon presentation to CIBC and CIBC WoodGundy Clients June 1st, 2011.
Shashi B. Malik presents to the Entrepreneurial CA’s of Calgary on “Restructuring for the Sale of a Business” March 16th, 2011.
Miller Thomson 2018 Construction Law Conference
Featuring: claims, blockchain, quantification of damages, insurance, AMF, tax, cannabis and more! Join us on Tuesday, March 20, 2018 for a daylong conference intended for all construction and real estate sector stakeholders and keep appraised of the most recent developments...
( Available in French only )
Vérifications fiscales… Évitez la catastrophe!
Tout entrepreneur doit savoir comment agir face à une demande de vérification fiscale de Revenu Québec ou de l’Agence du revenu du Canada. Lors de ce « Lunch & Learn » présenté à La Gare|Espace collaboratif, vous obtiendrez des conseils pratiques pour vous y...
Recent Tax Developments 2011 – Calgary
Miller Thomson’s Calgary Tax Group hosts a breakfast seminar on “Recent Tax Developments.”
Whistleblowers and the Evidentiary Challenges in Offshore Tax Evasion Cases
Canadian Tax Journal, Vol. 65, No. 3
The article provides a high-level overview and comparison of the US and Canadian whistleblower programs. Whereas the us experience has resulted in the recovery of significant unreported tax dollars and successful tax prosecutions, the Canadian whistleblower program has, to date, had limited success.
How Pharmacists Can Protect Themselves From the CRA in the Coming Years
Taxes & Wealth Management, Issue 9-1
Tax Evasion: Some Recent Global Developments
It's Personal (Preserving Wealth for People and Private Companies)
Including a report from the IBA.
A Brief Summary of the Post STEP Conference Session
It’s Personal (Preserving Wealth for People and Private Companies) Special Edition, Volume 5, Issue 3
CRA audit project targets high-net-worth individuals
The Lawyers Weekly, Vol. 30, No. 45, 13
2011 Federal Budget Minister of Finance Jim Flaherty today tabled the 2011 Federal Budget (the “Budget”) entitled “A Low Tax Plan for Jobs and Growth”. We are pleased to provide our summary of tax measures contained in the Budget. There...
Business Tax Measures
IN THIS SECTION: Manufacturing and Processing Sector: Accelerated Capital Cost Allowance Clean Energy Generation Equipment: Accelerated Capital Cost Allowance Qualifying Environmental Trusts Intangible Capital Expenses in Oil Sands Projects Stop-Loss Rules on the Redemption of a Share Partnerships – Deferral...
Customs Tariff Measures
IN THIS SECTION: Customs Tariff Simplification Facilitating Low Value Imports Customs Tariff Simplification The Federal Government announced the initiation of a process to simplify the Customs Tariff in order to facilitate trade and lower the administrative burden for businesses. This...
Personal Tax Measures
IN THIS SECTION: Children’s Arts Tax Credit Volunteer Firefighters Tax Credit Family Caregiver Tax Credit Medical Expense Tax Credit for Other Dependants Child Tax Credit Eligibility Tuition Tax Credit – Examination Fees Education Tax Measures – Study Abroad RESPs –...
Other Tax Measures
IN THIS SECTION: Aboriginal Tax Policy GST/HST Changes Aboriginal Tax Policy The Federal Government expressed its continued support of initiatives that encourage the exercise of direct taxation powers by Aboriginal governments including, in particular, the entering of arrangements respecting sales...