IBA Business Law International, Volume 3, Number 2, May 2022
An article by David Chodikoff and Justin Ng on “Canadian Civil Tax Disputes: Taxpayer Opportunities to Resolve Tax Issues” is featured in the IBA Business Law International publication. Published by the IBA’s Legal Practice Division, Business Law International is circulated globally and highlights legal developments from around the world.
In the article, the authors note that:
Civil tax disputes are primarily all about money. Occasionally, a Canadian Charter of Rights and Freedoms issue finds its way into the process of challenging the government’s taxpayer assessment, but it is not common. From the government’s perspective, a civil tax dispute generally involves a principled approach, applying both the language of the taxing statute and the relevant common law. More often than not, while a taxpayer seeks to comply with the law, the primary concern is how much will it cost; ‘What do I have to pay in tax, if anything?’ This dynamic sets the stage for the majority of civil tax disputes. No one needs to be told that challenging a tax dispute is an expensive, time-consuming and not entirely efficient process. In Canada, there are a few ways to resolve a tax dispute.
This article first appeared in the May 2022 issue of Business Law International (Vol 23, No 2), and is reproduced by kind permission of the International Bar Association, London, UK. © International Bar Association.