Tax Disputes Resolution


Miller Thomson’s Tax Disputes 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 Disputes 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 Disputes 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 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

Notable matters

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.

International Tax Review: World Tax Guide

Our Tax lawyers are recognized as ‘highly regarded’ in the 2024 ITR World Tax Guide – David Chodikoff in the area of Tax controversy and Cathie Brayley as a ‘Women in Tax Leader’.

Chambers Global Practice Guides Transfer Pricing 2023 – Canada: Law & Practice and Trends & Developments

Read about recent developments in Canadian transfer pricing including the rules governing transfer pricing, transfer pricing methods and the rise in Court intervention in transfer pricing disputes.

View the full chapter

Successful Tax Court of Canada Appeal

Ron Choudhury and David Chodikoff represented CanLII in a successful sales tax appeal, where the Tax Court of Canada found in favour of CanLII, on the basis that CanLII made a taxable supply with respect to the provision of a virtual library and are consequently entitled to claim input tax credits.


Stay Informed

Sign-up to receive electronic communications, including newsletters on legal developments, event invitations, firm news and more.