Savings: $2,300,000
Rosen & Associates negotiated a favourable settlement during a tax court hearing, saving our clients $2,300,000 in tax payable.
R
osen and Associates is a national tax law firm based in Toronto, Ontario. We take a proactive, client focused approach allowing our lawyers to provide comprehensive legal tax advice and representation.
Our focus and expertise is centered around the complex area of tax law, placing R&A Tax Law in a unique position to deliver the quality of service and legal tax defense rightfully expected by hardworking Canadians in their disputes against the Canada Revenue Agency.
If you are having trouble with the CRA or are experiencing taxation issues Rosen & Associates can help. We are especially skilled in the following practice areas:
Savings: $2,300,000
Rosen & Associates negotiated a favourable settlement during a tax court hearing, saving our clients $2,300,000 in tax payable.
Savings: $1,600,000
We saved our client over $600,000 in unpaid taxes and over $1,000,000 in penalties and interest for a sum of $1.6M in total savings.
Savings: $297,189
We assisted a client with a non-resident audit. We argued that the taxes they had previously paid should be refunded because the client was a non-resident of Canada for tax purposes, and should not have reported the income or paid the taxes on it. We were successful and got our client a refund of $297,189.
Savings: $24,000
Following our clients audit, and denial of their New Residential Rental Property Rebate, we filed a notice of objection arguing they were entitled to the Rebate. The CRA agreed with our objection and the Rebate was allowed in full.
Savings: $58,000
We assisted a client with a taxpayer relief request arguing that she deserved relief from the penalties and interest she was charged due to her life circumstances. CRA agreed and provided with full relief for all penalties and interest she had been charged since 2012.
The Minister raised a director’s liability assessment for unpaid taxes under the Retail Sales Tax Act. The taxpayer had effectively resigned more than two years prior to the aforementioned assessment being issued. By way of consent, the Minister vacated the assessment and revoked all legal action.
Our team was able to establish that our client acted with all due diligence. Accordingly, we were able to have the notices of reassessment vacated in their entirety and removed over $5.5 million in alleged unreported income, gross negligence penalties and penalties relating to foreign reporting.
The Taxpayer was assessed with business income of $635,843 for the sale of her investment property, and she was charged with gross negligence penalties. We filed a notice of appeal to the Tax Court of Canada, and reached a settlement with the Department of Justice. Her gain was re-characterized as a capital gain, and the gross negligence penalties were removed.
Amidst the Tax Court proceedings, we were able to negotiate an early resolution by way of a consent to judgment wherein the Minister allowed our client to rightfully deduct employment related expenses. In addition to reducing the taxable income by approximately $120,000, we also negotiated the removal of gross penalties, which was 50% of the tax otherwise payable on the above noted amount.
The Minister attempted to prevent our Clients, the Taxpayers, from appealing the CRA’s incorrect decision regarding GST/HST on the disposition of a rental property. Rosen & Associates was able to demolish the Minister’s position by proving that positive steps were taken by the Taxpayers to maintain their genuine intention to dispute the impugned decision and have their appeals heard on it’s merits.
We bring each client a combination of deep industry knowledge and expert perspectives from other industries on the challenge at stake, to offer our clients fresh perspectives and breakthrough business insights.
Fresh perspectives and breakthrough news from the world of tax law.
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