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Tax disputes can be daunting for any business. When faced with a Canada Revenue Agency (CRA) audit or a tax reassessment, companies need a lawyer who can provide not only competent legal defense but also practical guidance through the process. A successful tax litigation (or tax dispute resolution) lawyer will protect the company’s interests, navigate complex tax laws, and strive for the best outcome – whether that means negotiating a favorable settlement or fighti…
Understanding CCPC vs. Non-CCPC Status In Canada, a Canadian-controlled private corporation (CCPC) is generally a private corporation that is Canadian-controlled (generally not controlled by non-residents or public companies) and is a “Canadian corporation” (generally incorporated or resident in Canada). CCPC status confers certain tax benefits (like the small business deduction and enhanced R&D credits) but also imposes a high tax on passive investment i…
You must file a Notice of Objection to dispute an assessment issued by the Canada Revenue Agency (CRA). In Canada, this process applies under both the Income Tax Act (for income tax matters) and the Excise Tax Act (for GST/HST and certain other taxes). The T400A Notice of Objection form is used for income tax objections, while equivalent forms (e.g. GST159 for GST/HST) serve the same purpose under the Excise Tax Act. This comprehensive guide explains the purpose of…
The Canada Revenue Agency (CRA) is rolling out new security measures for its online services ahead of the 2026 tax season. Starting in February 2026, all CRA My Account and My Business Account users will be required to have a backup multi-factor authentication (MFA) option on file. In practical terms, this means that in addition to your primary MFA (such as receiving a code by phone), you must set up at least one secondary authentication method – for example, a pas…
The Canada Revenue Agency (CRA) sorts formal tax disputes (objections) into defined complexity levels – Low, Medium, High – each with its own expected processing timeframe. Understanding these categories and timelines is crucial for tax practitioners managing client disputes. Below is an overview of each complexity level and typical resolution times for income tax objections. Low Complexity Cases Low complexity income tax objections involve straightforward is…