Cassels

Canadian Corporate Law Firm

Tax & Trusts Law

The Tax & Trusts Group at Cassels brings knowledge, insight and innovation to both the technical and practical aspects of taxation to provide effective advice on a wide range of issues and transactions that are important to our clients and their business, including:

Corporate Tax

We pride ourselves on servicing a diverse local, national, and international client base, including large public corporations, partnerships and REITs, private corporations, financial institutions, private equity funds, professional service firms, and domestic and foreign governmental agencies.

Cassels tax lawyers are recognized for our broad, practical and in-depth expertise in:

  • Domestic and international mergers, acquisitions, reorganizations, spin-offs, restructurings and insolvencies
  • Foreign investment and business expansion into Canada
  • Securities matters, including all public and private offerings and “going public” transactions
  • Executive and employee compensation plans
  • Cross-border employment issues, including the drafting of secondment agreements, advising on the application of tax treaties and on the allocation of equity-based compensation between jurisdictions
  • Domestic and international tax dispute resolution, including assistance on all aspects of audits, appeals and settlement negotiations as well as “mutual agreement procedures” under international tax treaties
  • Sales and commodity tax issues

Clients engage the Tax & Trusts Group at Cassels with confidence that they will benefit from an interdisciplinary team that understands their business from all relevant perspectives and that strives to integrate the necessary tax advice in a seamless and practical manner. We have also been sought out by the Department of National Revenue and the Department of Finance for contributions to the development of tax policy and tax legislation.

Sales, Indirect, and Commodity Tax

Our Sales, Indirect & Commodity Tax team offers comprehensive legal services to businesses and organizations operating across all sectors of Canada’s economy. Our team includes lawyers experienced in all Canadian sales, indirect, and commodity taxes, including:

  • Goods and services tax/harmonized sales tax
  • Provincially imposed sales taxes in British Columbia, Saskatchewan, Manitoba, and Quebec
  • Taxes and duties on alcohol, tobacco, cannabis, and other regulated products
  • Taxes and duties on fuel, including carbon taxes and the federal fuel charge

Our team specializes in sales, indirect, and commodity taxes while supporting clients across all industries, enabling us to leverage sector-specific solutions for our clients in novel ways. We offer deep experience advising clients across a variety of industries, including:

  • Financial services (leasing and financing, fintech, insurance, crypto, private & public equity, banking, etc.)
  • Real property and infrastructure
  • Cross-border sales and activities
  • Retail and consumer goods
  • Technology and Telecommunications
  • Energy, natural resources, and manufacturing
  • Education and healthcare
  • Public sector

Our team offers a proven track record of success with:

  • Advisory and planning services
    • Supporting entry into the Canadian market
    • Novel business models and products
  • Transactional support
    • Expert tax advice in mergers and acquisitions, divestures, real property, investment structures, joint ventures, and other commercial transactions to minimize tax incurred
  • Tax Disputes
    • Audit defence and administrative appeals
    • Tax litigation, including judicial review, tax appeals, and appellate advocacy
    • Voluntary disclosures and other interactions with tax authorities

Our Sales, Indirect & Commodity Tax team can be counted on for industry-specific advice that understands your business imperatives, helping you minimize what you pay in sales and commodity taxes.

Tax Disputes & Litigation

Our Tax Disputes & Litigation team provides expert guidance and representation to businesses and individuals facing tax controversies. We help clients navigate the complexities of tax audits, assessments, and disputes with the Canada Revenue Agency (CRA) and other tax authorities, ensuring fair and timely resolutions.

Our team offers a proven track record of success with:

  • Tax Audits and Assessments
    • Audit Representation: Professional representation during CRA audits to ensure proper conduct and protect your interests.
    • Assessment Review: Detailed review of tax assessments to identify and challenge any inaccuracies or unfair assessments.
    • Negotiation and Settlement: Skilled negotiation with tax authorities to reach favorable settlements.
  • Tax Appeals
    • Notice of Objection: Preparation and filing of Notices of Objection to challenge CRA decisions.
    • Appeals Representation: Representation at all levels of the appeals process, including the Tax Court of Canada and the Federal Court of Appeal.
    • Strategic Advice: Expert advice on the best strategies to resolve tax disputes and minimize liabilities.
  • Tax Litigation
    • Court Representation: Experienced representation in tax litigation cases before the Tax Court of Canada, Federal Court, Federal Court of Appeal, and other judicial bodies.
    • Dispute Resolution: Administrative dispute resolution methods, including settlement conferences, to resolve tax disputes efficiently.
    • Complex Tax Issues: Handling complex tax issues such as transfer pricing, General Anti-Avoidance Rule (GAAR) cases, GST/HST, and international tax disputes.
  • Voluntary Disclosures
    • Voluntary Disclosure Program (VDP): Assistance with the VDP to correct past tax errors or omissions and avoid penalties.
    • Compliance Review: Comprehensive review of your tax situation to identify areas of non-compliance and recommend corrective actions.
    • CRA Negotiation: Negotiation with the CRA to ensure favorable terms under the VDP.
  • Tax Fairness Applications

Our team, including experienced tax professionals and former CRA advisors, prides itself on collaborating with clients to develop tailored strategies that meet their goals.

Comprehensive Approach

Our clients can expect a comprehensive approach to their tax needs. Where required, we also work in collaboration with experts from our Private Client team on estate planning, including cross-border planning and domestic and foreign charitable planning and, when necessary, bring in the expertise of our Charity & Not-for-Profit team.