Tax Services · For Business
Tax counsel for Canadian companies.
Corporate audits, GST/HST and payroll disputes, directors' liability, voluntary disclosures, cross-border tax — we deal with the CRA so you can run your business.
What we do for businesses
Tax counsel for Canadian companies.
Choose the service that fits your situation. Not sure? Book a free consultation and we'll point you to the right one.
Voluntary Disclosure
The Voluntary Disclosures Program lets Canadian taxpayers correct unreported income, unfiled returns, and undisclosed offshore assets before the CRA contacts them. A successful submission can eliminate gross-negligence penalties and the risk of criminal prosecution, while limiting interest exposure.
Learn moreUnreported Offshore Income
The CRA receives offshore account data from over 100 jurisdictions through the Common Reporting Standard. If you have unreported foreign income, dividends, rental income, or capital gains, voluntary disclosure is usually the only path to avoid gross-negligence penalties or prosecution.
Learn moreUnreported Domestic Income
Unreported tips, side-business revenue, cash payments, rental income, or freelance income can all be corrected through voluntary disclosure — often before the CRA flags an audit.
Learn moreUnreported Offshore Assets
Specified Foreign Property over $100,000 must be reported on Form T1135. Missed reporting carries severe penalties, but voluntary disclosure can substantially reduce or eliminate them.
Learn moreUnreported Cryptocurrency Transactions
The CRA treats cryptocurrency as a commodity. Disposals — including crypto-to-crypto trades, NFT sales, staking, and DeFi yields — generate taxable events. Unreported gains can be corrected through the Voluntary Disclosures Program.
Learn moreOverstated Expenses
Overstated business or rental expenses can be corrected through voluntary disclosure before the CRA reassesses, avoiding gross-negligence penalties and limiting interest exposure.
Learn moreCRA Audit Representation
From the first audit letter through proposal letters and reassessment, our tax lawyers manage the auditor on your behalf. We control the flow of information, conduct the audit at our offices when possible, and challenge errors before they become assessments.
Learn moreVoluntary Disclosure
If you have unreported income, unfiled returns, or undisclosed offshore assets, voluntary disclosure is usually the right move — but only before the CRA contacts you. Our lawyers run an anonymous eligibility review and draft a complete VDP submission.
Learn moreTax Court of Canada Representation
When a Notice of Objection is denied or running out of time, the Tax Court of Canada is the next forum. We handle Informal and General Procedure appeals from pleadings through trial.
Learn moreTax Disputes & Notices of Objection
A Notice of Objection must be filed within 90 days of a Notice of Reassessment (or one year for individuals seeking an extension). We draft objections that put your strongest legal arguments on the record and engage the CRA Appeals Division.
Learn moreBusiness Owner Tax Planning
Most Canadian business owners pay more tax than they need to — not because they're aggressive, but because the planning around their corporation, their compensation, and their eventual exit hasn't been touched in years. We build forward-looking tax plans that fit the business as it actually runs.
Learn moreEstate Freeze
An estate freeze caps the value of your corporation at today's fair market value in your hands, while issuing new growth shares to a family trust, your children, or another holding entity. Future appreciation accrues to the new shareholders — outside your estate, outside your eventual deemed disposition at death, and outside your share of any future tax-on-gain.
Learn moreCapital Gains Exemption
The Lifetime Capital Gains Exemption shelters over $1 million of gain on the sale of qualifying small-business-corporation (QSBC) shares — and, with proper planning, can be multiplied across family members. Most business owners qualify in principle; the planning value is in structuring early enough that the qualification tests are met when the sale happens.
Learn moreTax Arrears Negotiation & Payment Plans
If you owe the CRA and cannot pay in full, we negotiate realistic payment arrangements, halt aggressive collection, and pursue Taxpayer Relief for penalties and interest where appropriate.
Learn moreOwner Compensation Planning
The salary-vs-dividend question is the largest annual tax-planning lever for most owner-managed Canadian corporations. The right mix depends on the corporation's tax pools, the owner's other income, family situation, RRSP room, CPP profile, and intended use of the corporate cash. We review it every year.
Learn moreFamily Trust Planning
A discretionary family trust is the most flexible vehicle in Canadian tax planning. Used well, it allocates income to family members in lower brackets, holds growth shares so that future appreciation builds outside the founder's estate, and serves as the central tool for transferring control to the next generation. We design, settle, and administer family trusts as part of the broader business-and-estate plan.
Learn moreTax Crime Representation
Tax evasion and tax fraud charges from the CRA Criminal Investigations Program carry the risk of imprisonment, fines of up to 200% of tax evaded, and a permanent record. Engage counsel before speaking to investigators.
Learn moreHolding Company Strategy
A holding company sitting above the operating company is one of the standard Canadian corporate structures for business owners with meaningful retained earnings. It moves accumulated wealth out of the operating business (away from operating-creditor risk), enables tax-deferred dividend distributions, and creates the platform for future estate-freeze and capital-gains-exemption planning.
Learn moreSuccession Tax Planning
The tax planning for transferring a Canadian family business to the next generation can save hundreds of thousands of dollars — sometimes millions — when the structure is set up years before the transfer happens. We coordinate the estate-freeze, capital-gains-exemption, intergenerational-transfer-rule, and corporate-reorganization moves that produce a tax-efficient succession.
Learn moreTax Planning
Good tax planning happens years before a return is filed. We design family-trust, holdco, estate-freeze, and remuneration structures that lower lifetime tax while staying onside of GAAR and recent CRA positions.
Learn moreCharitable Giving
Canadian charitable-giving rules reward thoughtful donors generously — donations of publicly-traded securities are tax-free on the accrued gain, donations through a private foundation give the donor control over the gift's deployment, and large-gift planning can shelter the bulk of a transaction year's tax. The planning question is which asset, which vehicle, and when.
Learn morePost-Mortem Planning
When a Canadian shareholder dies owning private-company shares, the terminal T1 triggers a deemed disposition that often produces a significant capital-gains tax. Coordinated post-mortem planning — pipeline, bump, and loss-carryback — can recover much of that tax. The 36-month statutory window starts the day of death.
Learn moreTaxpayer Relief Applications
The Minister has discretion to cancel or waive penalties and interest in cases of extraordinary circumstances, CRA error, or financial hardship. We draft persuasive RC4288 applications grounded in the case law and IC07-1.
Learn moreInvestment Tax Planning
Where you hold an investment matters as much as which investment you hold. Asset-location decisions across TFSAs, RRSPs, RESPs, non-registered accounts, and corporate investment portfolios produce after-tax-return differentials that compound over decades. We coordinate placement strategy with the broader tax plan.
Learn moreTax-Efficient Sales
The single largest tax event in most business-owners' lives is the sale of the business. The difference between an unplanned and a planned sale is typically 25-40% of the after-tax proceeds. We work alongside the M&A team to design the sale structure two-to-three years in advance.
Learn moreUnfiled Tax Returns
Years of unfiled returns are a serious problem — but rarely the disaster taxpayers fear. Through voluntary disclosure or careful filing strategy, we bring you current and minimize penalties and interest.
Learn moreCorporate Restructuring
Canadian corporate tax law provides a suite of tax-deferred reorganization mechanics — Section 85 transfers, Section 86 share-class conversions, Section 87 amalgamations, Section 88 wind-ups, Section 51 conversions. Choosing the right one (and getting the election forms filed on time) is the difference between a successful restructure and a costly accidental tax trigger.
Learn moreNet Worth Audits
Net-worth audits estimate income from changes in your assets and lifestyle. They are inherently imprecise and frequently overstated. We rebuild the audit, identify auditor errors, and roll back unsupported additions to income.
Learn moreDirector's Liability
Directors can be held personally liable for unremitted GST/HST and source deductions. We raise the due-diligence defence, challenge the underlying assessment, and file timely Notices of Objection.
Learn moreTax Shelter & Donation Scheme Disputes
If you participated in a charitable donation tax shelter or other CRA-disputed arrangement, you may be facing reassessment with significant penalties. We defend participants individually and as part of group strategies.
Learn moreCross-Border Tax
Tax problems that straddle the Canada-US border are rarely solved by looking at one country at a time. Our cross-border practice, led by Simone Barrett — admitted in Ontario and Florida — coordinates Canadian and US federal tax positions so the two systems work together rather than against you.
Learn moreDeparture Tax
Canada's departure tax — the deemed disposition under Section 128.1 of the Income Tax Act — treats most of your worldwide assets as sold the day you leave. Planning ahead can defer the tax, post security in lieu of payment, or restructure holdings so the deemed gain is smaller.
Learn moreCross-Border Trusts
Trusts with one foot in Canada and one foot in the US carry a thicket of overlapping rules: Section 94 of the Canadian Income Tax Act, the US grantor-trust regime, throwback rules on accumulated income, FATCA reporting, and treaty residency. We design and remediate cross-border trust structures so each system reaches the conclusion you want.
Learn moreUS-Canada Estate Planning
Estate planning that crosses the Canada-US border touches Canadian capital-gains-at-death rules, US estate tax, QDOT planning for non-citizen spouses, and the Canada-US treaty estate-tax credit. Coordinated wills, beneficiary designations, and asset titling avoid the common double-tax traps.
Learn moreUS Estate Tax for Canadians
If you are a Canadian who owns US real estate, US-corporation shares, or other US-situs assets, US estate tax can apply at your death — even with no other US connection. The Canada-US tax treaty provides a prorated unified credit, but the math depends on the size of your worldwide estate and the value of your US-situs holdings.
Learn moreSnowbird Tax Planning
If you spend more than a third of the year in the United States across a rolling three-year window, the IRS can treat you as a US tax resident — exposing your worldwide income to US tax. The closer-connection statement (Form 8840) and the Canada-US treaty's residency tie-breaker keep most snowbirds on the Canadian side, but the analysis isn't automatic.
Learn moreFATCA & FBAR
A US citizen or green-card holder living in Canada is subject to US tax on worldwide income and to two parallel disclosure regimes — FBAR (FinCEN 114) for foreign financial accounts and Form 8938 (FATCA) for specified foreign financial assets — with penalty schedules that can dwarf the underlying tax.
Learn moreStreamlined Filing
If you're a US person who hasn't been filing US returns or FBARs and your non-filing was non-willful, the IRS's Streamlined Foreign Offshore Procedures provide a structured path to compliance: three years of amended Form 1040s, six years of FBARs, and a signed certification — without civil penalty if accepted.
Learn moreFIRPTA Withholding
Under the Foreign Investment in Real Property Tax Act (FIRPTA), a US buyer of US real estate from a non-resident foreign person must withhold up to 15% of the gross sale price and remit it to the IRS. The withholding is not the final tax — it's an advance against the actual US tax liability — but the cash impact at closing is substantial.
Learn moreSection 116 Clearance
A non-resident selling taxable Canadian property — Canadian real estate, shares of certain private Canadian corporations, partnership interests deriving value from Canadian real estate — must obtain a Section 116 clearance certificate from the CRA. Without it, the purchaser is required to withhold 25% (or higher, in some cases) of the gross sale price.
Learn moreNew-Resident Tax Planning
When you become a Canadian tax resident, paragraph 128.1(1)(b) of the Income Tax Act gives you a one-time fair-market-value cost-base reset on most of your worldwide assets — sheltering all pre-arrival appreciation from Canadian tax. The window for planning closes the day Canadian residency begins.
Learn morePre-Relocation Tax Planning
Canadian tax planning before a relocation focuses on minimizing the Section 128.1 departure-tax exposure, cleaning up account positions that would be tax-disadvantaged after the move (Canadian mutual funds, TFSAs, RESPs), and restructuring closely-held corporations while they're still under Canadian tax rules.
Learn moreCross-Border Real Estate
Whether it's a Florida condo bought by a Canadian or a Toronto rental held by an American, cross-border real estate structures have lifetime consequences for income tax, estate tax, capital-gains treatment, withholding obligations, and audit risk. Choosing the right structure at the purchase stage avoids costly restructuring later.
Learn moreCross-Border M&A
Cross-border deals between Canadian and US companies — Canadian buyer of US target, US buyer of Canadian target, cross-border merger of equals — bring tax issues that are routinely missed in the closing rush: treaty residency of the surviving entity, Subpart F / GILTI inclusions, branch profits tax, transfer pricing on integration, and the choice between asset and share deals.
Learn moreUS IRS Representation
Barrett Tax Law represents clients in US federal IRS examinations, Office of Appeals proceedings, and Florida-state tax matters. Simone Barrett is admitted in Florida (The Florida Bar) and Ontario (Law Society of Ontario), so she can represent clients in matters of US federal tax law, Florida state tax law, and Canadian tax law. For US-state tax matters outside Florida, the firm engages locally-admitted counsel.
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Also for businesses
Corporate & commercial services
Incorporations, shareholder agreements, corporate reorganizations, business sales & acquisitions, fractional general counsel, and more — browse the full corporate services hub →
Succession & Estates
Wills, Estates & Succession Planning
Plan the transfer of your business — to the next generation, to a buyer, or both — without handing the CRA more than it's owed.
Featured practice
WILLS & ESTATES
Estate freezes, family trusts, intergenerational transfers, US-Canada estate-tax exposure on US-situs assets, and post-mortem pipeline planning. We coordinate the will, the corporate structure, and the tax position so the plan actually does what the family expects.
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