Tax Disputes Lawyers

Did you receive a notice of assessment or reassessment you disagree with, a large bill after an audit, or a collections letter from the Canada Revenue Agency (CRA) or Revenu Québec? A tax dispute lawyer can tell you whether the assessment can be challenged, file your objection on time and take the case to court if it comes to that. On this page you can compare lawyers who handle tax disputes in Quebec, see their rates and availability, and book a consultation online.

What a tax dispute lawyer does

A lawyer in this area focuses on the moment a tax authority says you owe more than you think. That can mean reviewing an audit proposal before it becomes an assessment, preparing and filing a notice of objection, negotiating with the appeals officer, appealing to the Tax Court of Canada or the Court of Québec, asking for penalties and interest to be cancelled, and dealing with collection measures while the dispute is ongoing.

Tax disputes are one part of tax law. For tax planning, estates, business structuring or general tax questions, see our page on tax lawyers.

Two tax authorities, two paths

In Quebec, most people and businesses deal with two tax administrations. The CRA assesses federal income tax. Revenu Québec assesses Quebec income tax and the QST and, for most Quebec businesses, also administers the GST/HST on the federal government's behalf. Each authority issues its own assessments, and each one has to be contested separately, even when both come from the same audit.

The court also depends on the tax, not on who sent the notice. Federal taxes, including GST/HST assessed by Revenu Québec, are appealed to the Tax Court of Canada. Quebec taxes, such as Quebec income tax and the QST, are appealed to the Court of Québec.

The objection and appeal process, step by step

1. The proposal or assessment. An audit often ends with a proposal letter explaining the changes the auditor intends to make. Responding with documents and arguments at this stage can sometimes avoid the assessment altogether. If not, you receive a notice of assessment or reassessment.

2. The notice of objection. To contest, you file a formal notice of objection with the CRA, Revenu Québec, or both. The deadline is strict and short, and missing it can leave the assessment final. An extension can sometimes be requested, but it is not automatic. The objection should set out every issue and the facts that support your position, because it frames the rest of the dispute. The CRA explains how to file an objection, and Revenu Québec has its own forms and process.

3. Review by the appeals officer. At the CRA, objections are handled by the Appeals Division, which is separate from the audit team; Revenu Québec also has its own objection service. The officer reviews the file and often discusses a settlement. The result is a decision confirming, changing or cancelling the assessment.

4. Going to court. If you still disagree, you can appeal within another strict deadline. The Tax Court of Canada hears federal appeals and offers a simpler informal procedure for smaller disputes, alongside a general procedure for larger or more complex ones. Quebec tax appeals go to the Court of Québec. In some cases you can go to court if the tax authority takes too long to decide your objection.

Penalties, interest and taxpayer relief

Even when the tax itself is owed, penalties and interest can sometimes be reduced. Both the CRA and Revenu Québec can cancel or waive penalties and interest in certain situations, such as circumstances beyond your control, their own errors or delays, or a genuine inability to pay. These taxpayer relief (fairness) requests are separate from an objection and follow their own rules, and a refusal can be reviewed.

Collections while you dispute

Filing an objection does not always stop collection. For many income tax assessments, collection is generally put on hold while the objection or appeal is pending, but amounts such as GST/HST, QST and payroll deductions can usually be collected right away. Collection measures can include garnishing wages or bank accounts. A lawyer can help negotiate a payment arrangement while the dispute continues.

Voluntary disclosure and directors' liability

If you have unreported income, undeclared foreign assets or unfiled returns, both the CRA and Revenu Québec run voluntary disclosure programs. A disclosure that is accepted can lead to relief from some penalties and from prosecution, but it has to be made before the authority contacts you, and it has to be complete.

Directors of a corporation can also be held personally liable for certain unpaid corporate amounts, mainly payroll deductions and sales taxes. A director who acted with the care of a reasonably prudent person, or who resigned properly, may have a defence. A director's assessment is contested through the same objection and appeal route.

When to get a lawyer

• You received an audit proposal letter or a notice of reassessment with a large amount.
• The deadline to object is approaching, or you think it may have passed.
• The CRA or Revenu Québec rejected your objection and you are considering court.
• Collection measures have started, such as a garnishment of your bank account or wages.
• You are a director assessed for a company's unpaid deductions or sales taxes.
• You are thinking about a voluntary disclosure.

Preparing for your consultation

• Every notice of assessment or reassessment, and any proposal letter.
• Your correspondence with the CRA or Revenu Québec, including auditors' requests.
• The returns and supporting documents for the years in question.
• Any collection letters, payment arrangements or garnishment notices.
• A short timeline with the date you received each notice.

For tips on picking the right person, read our guide on how to choose a lawyer in Quebec.

Compare and book on JustiConnect

Browse the lawyers listed below, filter by location, rates, language and availability, and book a consultation directly. Each lawyer sets their own rates, and you can see them before you book. You can also search all tax dispute lawyers or see tax dispute lawyers in Montreal.

Frequently asked questions

Can I dispute a tax assessment myself?

Yes. Anyone can file a notice of objection, and individuals can represent themselves in the Tax Court's informal procedure. A lawyer becomes more useful when the amount is significant, the facts are complex, or the case is heading to court.

How do you fight a CRA reassessment?

By filing a notice of objection on time, with the facts and documents that support your position, and then appealing to the Tax Court of Canada if the objection is refused.

Does an objection stop the CRA from collecting?

For many income tax amounts it is generally paused, but not for sales taxes or payroll deductions. Interest keeps running, so some people pay and then object.

Is my file heard by the Tax Court of Canada or the Court of Québec?

It depends on the tax. Federal taxes, including GST/HST, go to the Tax Court of Canada. Quebec income tax and the QST go to the Court of Québec.

What if I missed the deadline to object?

You may still be able to ask for an extension of time, but that request also has a strict limit and conditions. Speak to a lawyer as soon as possible.