How we help
- IRS examination representation (correspondence, office, field audits)
- IRS Office of Appeals representation
- US Tax Court petitions
- Streamlined Foreign Offshore submissions for past non-filing
- Florida Department of Revenue audits and appeals
- Florida sales-and-use tax issues for Canadian sellers
- Coordination with Canadian CRA-side proceedings
What we handle on the US side
The US side of Barrett Tax Law's practice covers federal IRS proceedings — examinations of US returns, Office of Appeals representation, US Tax Court petitions, and Streamlined Foreign Offshore submissions for past non-filing — and Florida state tax matters (Florida Department of Revenue audits, sales-and-use tax, and the rare corporate income-tax issue).
For matters arising under the state tax law of US jurisdictions other than Florida, we coordinate with locally-admitted US counsel and provide the Canadian-side support. Many of our matters that begin as US-federal disputes also have a Canadian counterpart (a CRA examination on the same income or asset), and we handle both sides under a single engagement.
IRS examinations
IRS examinations come in three flavours: correspondence audits (mailed letters asking for documents), office audits (in-person at an IRS office), and field audits (the examiner comes to the taxpayer's location). For Canadian clients, almost all IRS audits are correspondence audits — the IRS does not typically dispatch examiners to non-US addresses. The work consists of responding to information document requests (IDRs), reconciling the position taken on the return with the records, and negotiating where the examiner proposes adjustments.
Most audits resolve at the examiner level. Where they don't, the IRS issues a 30-day letter offering the taxpayer the right to appeal to the IRS Office of Appeals — a separate, independent unit within the IRS that often resolves disputes the examiner couldn't. The 90-day statutory notice of deficiency comes after Appeals, and Tax Court is the next stop.
IRS Office of Appeals
Appeals is the most cost-effective forum for resolving a US tax dispute. Appeals officers are typically more senior than examiners, have hazards-of-litigation authority, and are tasked with resolving cases without litigation where possible. Cases that look intractable at the examiner level routinely settle at Appeals on terms materially better than the proposed adjustment.
US Tax Court
If Appeals doesn't resolve the case, the taxpayer has 90 days from the notice of deficiency to file a petition with the US Tax Court. Tax Court is a non-Article-III court that hears tax disputes; small-tax-case procedures are available for disputes under US$50,000 per year. The taxpayer doesn't have to pay the proposed deficiency before filing — unlike the Court of Federal Claims or the US District Court route, which require pre-payment.
Florida Department of Revenue
Florida's state tax issues mostly involve sales-and-use tax (Florida has no individual income tax, but a 6% sales tax with substantial complexity around what's taxable). Canadian sellers shipping into Florida through online marketplaces, Canadian companies opening Florida offices, and Canadian individuals buying tangible personalty in Florida all encounter the rules. Florida DOR audits work much like IRS audits — request, response, adjustment, appeal — with state-specific procedures.
How we work the file
Most engagements are billed on a fixed-fee or capped-fee basis once the scope is clear. We respond to IRS or Florida DOR information requests, attend the relevant proceedings (telephonically for cross-border clients), and pursue Appeals and Tax Court as needed. Where the same income or asset is also under examination by the CRA, the two engagements run together so the positions are coordinated and consistent.
What to expect when you call us
Your first call is a free, no-obligation consultation with a tax lawyer. We will review the details of your situation, explain your options under the Income Tax Act and CRA administrative practice, and give you a clear, fixed-fee quote if you choose to retain us. Your consultation is confidential, and once we are retained, communications are protected by solicitor–client privilege.
If you retain us, we begin work within 24 hours of being retained.
Frequently asked questions
Is the consultation really free?
Yes. Most cases qualify for a free, no-obligation consultation with one of our tax lawyers. During the call we'll review your situation, explain your options, and give you a clear quote if you decide to retain us.
What does a tax lawyer do that an accountant does not?
A tax lawyer focuses on the legal side of tax — disputes, litigation, and the structuring of transactions in light of the law and anti-avoidance rules. That includes representing taxpayers in CRA audits and objections, appearing at the Tax Court of Canada, defending penalties and director or derivative liability, and designing reorganizations such as section 85 rollovers and estate freezes.
The most practical distinction is privilege. Communications with a lawyer are generally protected by solicitor-client privilege, while communications with an accountant generally are not and can be demanded by the CRA. Where the facts are sensitive or the matter could become contentious, that protection matters.
Lawyers and accountants often work together — the accountant on the numbers and filings, the lawyer on strategy, privilege, and the legal record. Barrett Tax Law regularly coordinates with a client's existing accountant.
Do you serve all of Canada?
Yes. Barrett Tax Law represents clients across Canada. We have offices and local phone lines in Toronto, Calgary, Edmonton, Fort McMurray, Ottawa, Vancouver, and Winnipeg, plus a national toll-free line at 1-877-882-9829.
Who is Barrett Tax Law and what areas does the firm handle?
Barrett Tax Law is a Canadian boutique tax law firm that represents individuals and businesses in their dealings with the Canada Revenue Agency. The firm's work spans CRA audits and disputes, voluntary disclosures, Tax Court of Canada litigation, collections matters, and corporate and estate tax planning.
The firm was founded in 2009 and has represented many thousands of clients across Canada. Its head office is in Concord, Ontario (Vaughan), and it serves clients nationwide. You can reach the firm toll-free at 1-877-882-9829 (1-877-8-TAXTAX).
Most matters qualify for a free, no-obligation consultation, and most are quoted on a fixed-fee basis once scope is understood, so the cost is known before work begins.
What does a tax lawyer do that an accountant cannot?
Accountants prepare returns and financial statements. Tax lawyers represent you when those returns are challenged, audited, or prosecuted — and our communications are protected by solicitor–client privilege, which accountant communications generally are not.
What should I do if I receive a letter from the CRA?
First, identify what the letter is and what it requires. A CRA letter may open an audit, ask for documents, propose adjustments (a proposal letter), confirm a reassessment, or start collection action — and each carries its own deadline and its own implications. Note any date by which a response is required.
Do not ignore it, and be careful about responding off the cuff. What you say and produce can shape your later objection and appeal position, and casual admissions can be difficult to undo. If the letter proposes adjustments or penalties, or if significant amounts are involved, get advice before responding.
A free consultation can help you understand the letter, the deadline, and the right next step. Acting early — while options are still open — is usually far better than waiting until a deadline is near.
Will the CRA criminally prosecute me?
Most CRA disputes are civil. Criminal prosecution is reserved for serious tax evasion or fraud, usually involving deliberate misrepresentation. If you have unreported income, a voluntary disclosure is one of the standard ways to reduce criminal-prosecution risk.
Is the first consultation really free?
Yes. Most matters qualify for a free, no-obligation consultation with an experienced tax lawyer. The consultation is a chance to describe your situation, get a clear sense of the options and likely path, and receive a fee structure in writing before you commit to anything.
You can reach the firm toll-free at 1-877-882-9829 (1-877-8-TAXTAX) to arrange a confidential consultation. The head office is in Concord, Ontario (Vaughan), and the firm serves clients across Canada.
Are my communications with a tax lawyer confidential?
Yes. Communications between you and your lawyer for the purpose of obtaining legal advice are generally protected by solicitor-client privilege, one of the most strongly protected confidences in Canadian law. In practical terms, the CRA generally cannot compel disclosure of privileged communications.
This is an important difference from working with an accountant or other non-lawyer representative, whose communications and working papers can generally be demanded by the CRA. Where the facts are sensitive — unreported income, offshore assets, or potential penalties — that protection can be significant.
Privilege has limits and can be waived inadvertently, so it should be handled with care. A consultation can explain how privilege applies to your particular situation.
How fast can you start on my case?
We typically begin work within 24 hours of being retained. For audit deadlines, Notices of Objection, and other time-sensitive matters, we move immediately.
What if I have unfiled tax returns from many years ago?
We routinely handle 5+ years of unfiled returns. Through the Voluntary Disclosures Program — applied for before the CRA contacts you — we can usually eliminate gross-negligence penalties and limit interest exposure.