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

COVID-19 Resources

We have written on a variety of topics to help identify the pertinent issues, understand the legal implications, minimize risk exposure and manage legal obligations.


Successful Tax Court of Canada Appeal

David Chodikoff and Ron Choudhury 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.


Leading tax lawyer

Proud to announce Partner David Chodikoff has been recognized as a ‘highly regarded’ practitioner in the area of tax controversy by International Tax Review’s Tax Controversy Leaders: Guide to the World’s Leading Tax Controversy Advisers.


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