Whether your tax issues involve income taxes, transfer pricing, indirect taxes or other taxes, KPMG’s Dispute Resolution & Controversy Services team can help.
We assist companies, professionals and high net worth individuals to protect against, prepare for, and respond to challenges by the various tax authorities.
We are experienced in stages of the tax dispute – from pre-transaction analysis and documentation to tax litigation in the Supreme Court of Canada. We work with you to help lessen the likelihood of a challenge or audit before a dispute arises and to resolve matters that ultimately become the subject of a dispute.
Our approach is designed to cut through the complexity of dealing with tax disputes through effective strategies for their mitigation and management including resolution via the litigation process, if necessary.
- Obtaining technical rulings, advance pricing arrangements, opinions, clearances and waivers in advance of your transactions
- Preparing documentation and files to support tax positions in anticipation of future tax authority’s request for information
- Navigating voluntary disclosure, advance compliance and other tax authority programs.
- Negotiating audits, responses to audit queries, and administrative and judicial appeals
- Responding to the CRA or other tax authority demands for information or documentation
- Engaging with the CRA or other tax authority to agree on a project-based approach to progressing issues collaboratively
- Working with senior CRA or other tax authority officials to help ensure stated administrative policies and procedures are followed.
- Making informed decisions on preferred options for resolving difficult disputes, e.g. alternative forms of dispute resolution, settlement, and, if needed, litigation
- Helping finalize settlements and ensure appropriate documentation in collaboration with the tax authority
- Managing the tax dispute resolution process in a non-confrontational and effective manner.
KPMG in Canada along with our affiliated law firm, KPMG Law LLP, is authorized to perform legal services and is well equipped with professionals in tax litigation. Our highly trained professionals have years of experience working with tax authorities and in private practice.
We can help you handle your tax dispute effectively. By identifying potentially contentious issues early in the process, we can help save you time and money. We’re with you throughout the process.
Please contact Paul Lynch – a former CRA official who has been recognized by the International Tax Review as a leader in dispute resolution.