Tax Litigation
Expertise to resolve your tax disputes and protect your interests.
Assistance to taxpayers during audits conducted by tax authorities to ensure their rights are respected. In case of disagreement with an assessment, filing a notice of objection to challenge the decision and request a review.
Defense of taxpayers before the competent courts in tax disputes, whether related to taxes or charges of fraud or tax evasion.
Utilizing the administrative mechanisms provided by law to challenge a tax decision before considering legal action, with the aim of achieving a quick and effective resolution.
Seeking negotiated solutions with the CRA and the QRA to avoid lengthy and costly procedures, while considering the taxpayer's interests.
Regularizing a tax situation by cooperating with the authorities through the voluntary disclosure program, helping to avoid severe penalties and prosecution.
Assistance to taxpayers facing financial difficulties in negotiating payment arrangements or utilizing remedies available in cases of insolvency, including protection against excessive claims from tax authorities.
Challenging sales tax assessments and defending taxpayers in cases of disputes over the application of tax rules.
Analysis and challenge of the methods used by tax authorities to estimate presumed income, including net worth, bank deposits, and cash flow.
Review and challenge of abusive or unreasonable tax decisions before the courts to ensure the protection of taxpayers' rights.
Interpretation and application of rules regarding associated companies and dependency relationships that influence access to reduced tax rates and tax credits.
Assistance on the tax implications of trusts, including their tax residency and the obligations of beneficiaries and trustees.
Determining the tax residency status of individuals, corporations, and trusts to avoid double taxation or excessive assessments.
Assistance in challenging the denial of tax credits in various sectors, including:
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Scientific Research and Experimental Development (SR&ED) Tax Credit
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Investment Tax Credit
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Quebec Film and Television Production Tax Credit
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Tax Credit for the Modernization of a Tourist Accommodation Facility
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Refundable Tax Credit for Losses
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Refundable Tax Credit for Mining Resources
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Challenging assessments issued outside of the prescribed deadlines and analyzing the burden of proof requirements to effectively defend taxpayers.
Defense of taxpayers facing significant penalties or charges of tax fraud, including analysis of justifications and available remedies.
Determining the nature of income (capital gain vs. business income), a key factor influencing the applicable tax rate.
Liability of directors in the case of unpaid tax debts and defense strategies to limit their personal liability.
Challenging tax adjustments applied to transactions between related parties, ensuring compliance with transfer pricing rules and other tax principles.
Legal and tax solutions for managing significant tax debts, including restructuring and insolvency remedies.
Challenging aggressive collection measures taken by the CRA or QRA, such as asset seizures or the imposition of a legal lien.
Analysis of expenses rejected by tax authorities and justification of their eligibility according to applicable tax rules.
Compliance with employer tax obligations and challenging assessments issued in case of errors in withholdings at source.
Determining a worker's tax status and challenging reclassifications imposed by tax authorities, which impact social charges and taxes.
The possibility of reducing or canceling interest and penalties due to exceptional circumstances, such as administrative errors or financial difficulties.
Using business losses to reduce payable taxes, in compliance with tax rules on carryforward and carryback.
Negotiation and remedies to reduce interest on tax debts, including administrative adjustments or payment agreements.
FDG Avocats supports you throughout every stage of your tax dispute, whether at the federal or provincial level. We advise you on the best strategies to defend your rights and interests. We assist in preparing and presenting your arguments, evidence, and claims. We defend you with rigor and efficiency before the competent judicial authorities.
FDG Avocats supports you throughout every stage of your tax dispute, whether at the federal or provincial level. We advise you on the best strategies to defend your rights and interests. We assist in preparing and presenting your arguments, evidence, and claims. We defend you with rigor and efficiency before the competent judicial authorities.
Tax Lawyer in Montreal
As a former prosecutor for the CRA, Me Félix-Desbiens-Gravel has developed a deep understanding of the Canadian tax system and built strong relationships with tax authorities. Today, he leverages this knowledge and these connections to serve taxpayers, protecting their interests and optimizing their tax situation.
As a former prosecutor for the CRA, Me Félix-Desbiens-Gravel has developed a deep understanding of the Canadian tax system and built strong relationships with tax authorities. Today, he leverages this knowledge and these connections to serve taxpayers, protecting their interests and optimizing their tax situation.
