Canada Revenue Agency tax dispute statistics

Settlement, Withdrawal & Adjudication
Canada Revenue Agency tax dispute statistics

The Canada Revenue Agency Appeals Branch provided our firm with the following statistics related to the number of tax dispute and tax litigation files along with the rates of settlement, withdrawal and adjudication.

In June 2012, the CRA reported that:

  • the CRA Appeals Branch receives between 80,000 and 110,000 notices of objection to dispute tax reassessments;
  • approximately 90% of taxpayer notices of objection relate to income tax matters;
  • approximately 92% of notices of objection are resolved at the objection stage (Nota bene. The CRA did not define “resolved” and the meaning of “resolved” is unclear e.g., the CRA did not break-out the percentage of taxpayers who abandoned their files and the percentage taxpayers who were successful in whole or in part and decided to discontinue their tax appeal);
  • in or about 8% of taxpayers who filed notices of objections to reassessments chose to appeal the CRA’s decision to the Tax Court of Canada; and
  • in or about 1/3 of the appeals in the Tax Court are abandoned, 1/3 are settled and 1/3 are adjudicated.

Insights

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What Accountants Say

Peter Aprile is a very hands on and practical tax lawyer who is very focused and diligent. He is a pleasure to work with.

- Susan Farina, Tax Partner, Price Waterhouse Coopers

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What Clients Say

I’m a Senior VP with an accounting and finance background. I’ve worked with lawyers and large law firms. I was referred to Counter to fix a tax dispute. It is very rare to encounter lawyers that combine expertise, dedication, and a businesslike approach to litigation. I have no hesitation in recommending Counter.

- David Cuddy, Senior Vice-President, Finance & Business Operations, CFL

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What Accountants Say

Counter Tax Litigators has worked with Fuller Landau to resolve several of our clients’ tax disputes. Counter delivers superior communication.

- Laura Couvrette, CPA, CA, Fuller Landau LLP

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What Clients Say

I spent a good part of my career dealing with attorneys on innumerable matters, and found Peter to be extremely competent, open-minded and exceptionally honest. I would not hesitate to use Peter again, and highly recommend the team at Counter Tax Litigators.

- Mark Ram, Retired CEO

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What Clients Say

Counter’s representation on our behalf was well informed, professional and efficient, which ultimately resulted in a highly satisfactory decision in all aspects.

- Klaus W. Reif, President, Reif Estate Winery

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What Clients Say

I was amazed with the results. They went above and beyond, and I would recommend Counter to any person or business with a significant tax dispute.

- Brian Grott, Northland Screen Corp

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Recognition

Our law firm and tax lawyers regularly receive
recognition as leaders in tax controversy and litigation.

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