Will you be able to help?
- A) If you have been treated unfairly and the limitation periods have not expired, the short answer is yes, almost certainly, but not guaranteed.
- B) On the other hand, it may be that a client is not treated unfairly, at all. The problem is that even fair treatment will have serious adverse financial or more serious consequences. The client wants a “better than fair” treatment. In such circumstances, there may be nothing that can be done.
- C) However, it is sometimes possible to lesson the adverse impact, sometimes dramatically and particularly when we are involved early in the process. One simple example is the so-called “Tax Amnesty” or the Voluntary Disclosure Program ("VDP"). If available, that program can be very useful, if carried out carefully. This program and other, more sophisticated strategies, are best discussed in an initial consultation protected by Solicitor-Client Privilege.
- D) Time is always a critical element. For example, the VDP is only available if you apply before enforcement action has started. And there are other important limitation periods regarding assessments that could prevent you from having any chance to make fresh argument. The date of the mailing of a notice of assessment or reassessment is often a key date and the date a decision is rendered, if the matter was appealed, is often another key date. Do not delay. Contact Us today.
- E) No one can guarantee you a particular result. This is because an improvement in your circumstances will depend upon whether the audit, collection or appeal officials at the CRA or a Judge of the Tax Court of Canada can be persuaded that you are entitled to be treated differently. No one can guarantee that another person will be persuaded.