Tax Controversy & Litigation

Businesses are facing heightened regulation and more onerous disclosure obligations in the current Canadian tax environment. Against this backdrop of increased government scrutiny and more complex compliance requirements, tax controversies are on the rise, both within and beyond the courtroom.

Our Tax Controversy & Litigation group advises clients at all stages of the dispute resolution process, including through sensitive tax audits, formal tax appeals, alternative dispute resolution procedures and negotiations with tax authorities, and in litigation before the courts.

We represent clients in all types of Canadian federal and provincial tax matters, such as those involving income taxes, sales tax, customs and tariff matters, excise duties, and withholding and other tax matters.

Taking a proactive, client-focused approach, we provide effective and strategic representation that leads, in many cases, to a favourable resolution without resorting to the court process. When resolution is not possible at the audit or administrative appeal levels, our tax litigation team leverages its courtroom skills to successfully represent clients at all levels of court, both federal and provincial.

Our specialized national team has extensive experience dealing with the full spectrum of tax issues faced by Canadian businesses in all key sectors of the economy. This includes major cases involving transfer pricing, the general anti-avoidance rule (GAAR), specific statutory anti-avoidance rules and tax treaty matters. Our team is also experienced in managing complex and sensitive tax audits, and we regularly advise on strategies for appropriately navigating the audit process, before potential tax disputes are allowed to crystallize. We address issues relating to the scope of tax audit and requirement powers, claims and disputes involving privilege, and tax-related exchange of information.

In addition to advocating for clients, our lawyers are deeply involved in the Canadian tax community, being active members of professional organizations such as the Canadian Tax Foundation and the International Fiscal Association. They also serve on committees involving officials from federal and provincial tax authorities and Canadian courts, and frequently present and write on current tax issues. Our thought leadership allows us to seamlessly develop and leverage our resources to maximize the impact that we can have before government decision-makers in preventing, addressing and resolving tax disputes.

Companies facing audits, appeals or litigation retain Blakes because of our successful track record in effectively and efficiently resolving tax controversies. We are trusted for our commitment to providing practical legal representation that is sensitive to our clients' business priorities.