Tax & OtherLawyer referralTax disputes

CRA audit defence (complex)

Representation in a complex CRA audit.

Objections and Tax Court appeals usually must be filed within 90 days of the relevant CRA notice (individuals sometimes have longer to object), so do not wait. Ontario Done by an Ontario lawyer, by referral

What is included

  • Reviews the audit, proposal, reassessment or confirmation and your records
  • Works with your accountant on the facts and figures
  • Prepares notices of objection and responses to CRA
  • Files and argues an appeal in the Tax Court of Canada under the general procedure
  • Negotiates settlements with CRA or the Department of Justice

What is not included

  • Government, court or registration fees and other disbursements
  • Accounting, appraisal or other independent reports
  • Work beyond the scope in the lawyer's written retainer

Who this service is for

  • Individuals and businesses under a complex CRA audit
  • Taxpayers appealing a reassessment

Information to have ready

  1. 1All CRA letters, proposals and reassessments
  2. 2Tax returns and supporting records
  3. 3Your accountant's contact information
  4. 4Any notice of objection already filed

How a referral works

  1. 1Tell us in a few words what the matter is about, and who else is involved, so we can check for a conflict of interest.
  2. 2We recommend an Ontario lawyer for your matter, and at least one other you could choose instead.
  3. 3The lawyer runs their own conflict check, confirms the scope and quotes the fee, normally in a written retainer agreement.
  4. 4You pay the lawyer's fee to the lawyer. Any referral fee comes out of it, is disclosed to you in writing, and never increases what you pay.

NEO Legal Services Professional Corporation is a licensed paralegal firm, not a law firm. Every step of a referral, and your rights

Frequently asked questions

What does the lawyer charge?

Lawyers usually charge $350–$650/hr for this kind of work, by the hour. The lawyer quotes the actual rate and an estimate. You pay the lawyer directly; the referral itself costs you nothing.

What is the general procedure?

The Tax Court of Canada's full process for larger or more complex appeals, with formal rules, discovery and a trial. Smaller appeals can often use the informal procedure.

Should I talk to the CRA auditor myself?

You can, but what you say becomes part of the file. For a complex audit, getting advice before meetings or written answers is usually wise.

General information only, not legal advice. NEO Legal Services Professional Corporation is a licensed paralegal firm regulated by the Law Society of Ontario.

Important limitations

  • No outcome can be guaranteed
  • Deadlines keep running during a referral
  • The lawyer confirms the scope, fee and steps in a written retainer before starting
Law Society of Ontario — Barreau de l'Ontario
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