Tax court hearing
Savings: $2,300,000
Rosen & Associates negotiated a favourable settlement during a tax court hearing, saving our clients $2,300,000 in tax payable.
Fighting on behalf of our clients
Notice of Reassessment
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.
Property Sale Assessment
Savings: $600,000
The CRA audited our client on a property sale transaction where the proceeds of disposition were $4.5 million dollars; the CRA intended to charge GST/HST on the sale. We successfully had the audit closed, and the CRA agreed with our position, ultimately saving the client nearly $600,000 in taxes.
Remissions Request Reassessments
Savings: $950,000
We saved our client nearly $950,000 in corporate income tax reassessments following a successful remissions request and T2 adjustments.
Redetermination of Residency Status
Savings: $183,000
The CRA assessed our client as a resident of Canada for tax purposes. However, not only was our client a non-resident for tax purposes, but they were also subject to an International Tax Agreement, designed to prevent double taxation. We successfully submitted representations requesting a redetermination of our client’s residency status which was accepted in full, removing approximately $183,000 in taxable income.
Net worth audit
Savings: $513,000
A client came to us following a net worth audit. We drafted a notice of objection with legal representations arguing the audit results were incorrect. We were then successful in having $513,000 removed from the assessed amount owing.
Objection
Savings: $1,100,000
Following an objection done by Rosen & Associates, a client of ours went from owing the CRA over $500,000 to a refund of over $645,000. The CRA agreed that multiple property sales were not taxable and the taxpayer was entitled to the Principal Residence Exemption. An overall savings of $1,100,000.
Notice of Objection
Savings: $659,298
We assisted our client with a notice of objection arguing that the CRA was incorrect in denying all of their business expenses. We were successful in full, which resulted in a $659,298 refund to our client since they had paid the balance owing previously.
Notice of Objection
Our client was audited and was assessed as a builder for the sale of her property, which meant she had to charge GST/HST on the sale price of her home. We objected and had the decision reversed in full.
New Housing Rebate (NHR)
Savings: $24,000
The CRA denied our client’s GST/HST New Housing Rebate (NHR) application. We filed a Notice of Objection which was successfully accepted in full, ultimately saving our client over $24,000
Notice of Objection
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.
Notice of Objection
Savings: $30,000
Our client’s foreign tax credits were denied. We filed a notice of objection and had the credits allowed in full.
Notice of Objection
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.
Taxpayer Relief Request
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.
Tax court
Savings: $490,000
A client came to us after being assessed over $470,000 of GST/HST owing for the sale of a home. We filed a notice of appeal to the Tax Court of Canada and were able to prove that GST/HST was not chargeable on the sale of the home.
What was a $470,000 debt to the CRA turned into a $490,000 credit. Meaning, the client was refunded $19,000.
Notice of objection
Savings: $70,000
Our client came to us needing help, and we fought hard and got over $70,000 removed following our notice of objection. The CRA agreed that the unreported income they previously assessed did not exist.
TFSA Relief Request
Savings: $25,000
Our client was assessed a penalty for over contributing to his TFSA. We drafted and filed a TFSA Relief request, and the penalty was removed in full.
Notice of Objection
Savings: $87,000
A taxpayer came to us after her input tax credits were denied. The CRA had audited her, and came to the conclusion that her business was a sham. We filed a notice of objection and had the audit decision overturned. This resulted in the CRA allowing the input tax credits that had been denied.
Notice of Objection to Net Worth Assessment
Savings: Over $350,000
Following a net worth audit, we assisted our client with a notice of objection. We successfully removed almost the entire assessment following a notice of objection. Our client went from having over $757,000 of income, down to $7,000.
Taxpayer Relief
Savings: $50,000
R&A Tax Law filed a taxpayer relief request for a client who filed his taxes late for a number of years. We were successful in full with the late filing penalties, and all interest being cancelled. This will result in tax savings of over $50,000.
Canada Child Benefit Audit
Savings: $44,000
The CRA ruled that a single parent was not entitled to the Canada Child Benefit that she had been receiving and stopped the payments. We stepped in, reopened her audit, and had the decision overturned. As a result, our client received $44,000 in back-pay for the unpaid benefits.
Audit
Our client was being audited for the sale of two homes. We drafted representations arguing the client was entitled to the Principal Residence Exemption in both cases, and convinced the CRA to close the audit with no changes.
Taxpayer Relief
Our client was hit with an extremely large amount of penalties and interest due to the late filing of a 2014 personal tax return. We filed a taxpayer relief request and CRA agreed to provide relief of almost $100,000 which was removed from the amount owing.
Notice of Objection
Savings: $700,000
Our client went through a net worth audit, and the CRA reassessed her 2014, 2015, 2016, and 2017 tax years adding over $1,500,000 of unreported income. We filed a notice of objection and successfully removed the entire net worth assessment. The $1,500,000 of unreported income was removed in full, which meant a tax savings of $700,000.
Tax Court Hearing
Savings: $425,818
Rosen & Associates filed a notice of appeal on behalf of a taxpayer where he was charged with taking a $425,818 shareholder benefit from his company, and gross negligence penalties. After completing the litigation steps, we successfully negotiated the removal of the shareholder benefit and the gross negligence penalties thus avoiding the expensive costs of a hearing at the Tax Court.
Notice of Objection
The CRA denied our client’s Input Tax Credits because they claimed he was an agent acting on behalf of a foreign principal. We filed a notice of objection arguing that was not the case, and we were successful in full. This lead to a result of a refund of over $250,000 for our client.
Notice of objection
Savings: $447,000
Our client was assessed over $400,000 of GST/HST on the sale of his home. We filed a notice of objection arguing he should be exempted from GST/HST and we were successful in full. Not only did we remove all of the amounts owing, but our client received a refund of over $20,000 as well.
Notice of objection
Savings: $800,000
As a result of Rosen & Associates intervention, gross negligence penalties were removed, taxable income was lowered and many previously denied expenses were allowed. Our client went from owing nearly $800,000 to the CRA, to a refund position.
Notice of objection
Savings: $70,000
Our client, a real estate agent, was denied her business expenses following a CRA audit. We assisted with a notice of objection and were able to get her expenses allowed in full. This resulted in a $70,000 refund being paid back to her.
Notice of objection
Savings: $200,000
Rosen & Associates got involved at the appeals stage, and we have removed nearly $200,000 from the taxpayers income. The CRA agreed with our representations and allowed additional business expenses.
Audit
Savings: $200,000
We were able to remove over $200,000 from a potential CRA GST/HST assessment due to our audit submissions.
Payment plan
Savings: Structured payment plan
Dealing with CRA collections can be tough. This letter shows a payment plan we got for one of our clients to ensure that no legal action was taken against them.
Notice of objection
Savings: $28,000
Following a Rosen & Associates objection, our client saved over $28,000 in taxes. The CRA agreed with our submissions that gross negligence penalties should be deleted and additional business expenses should be allowed.
Notice of objection
Savings: $200,000
After a notice of objection, we were able to save our client nearly $200,000. The CRA agreed that the sale of their home was subject to the Principal Residence Exemption.
Notice of objection
Savings: $155,000
Following a Rosen & Associates objection, we were able to remove over $155,00 from our client’s CRA balance. We were able to successfully argue the unreported income claimed by the CRA did not exist.
Notice of objection
Savings: $140,000
We saved our client over $140,000 after objecting to the CRAs audit results. We successfully proved to the CRA their net worth audit was incorrect.
Net worth audit
Savings: $300,000
A client came to Rosen & Associates after a net worth audit owing the CRA over $300,000. Due to our intervention, that client now owes a little under nine dollars because the CRA agreed that a net worth audit was not correct and reversed its entire position.
Tax Court Hearing
Savings: $889,000
Rosen & Associates negotiated a settlement with the Department of Justice where our client’s net worth audit was reversed in full. This resulted in a refund paid back to our client of almost $900,000.
Notice of objection
Savings: $45,000
A client came to Rosen & Associates after battling with the CRA for three years.
We were able to prove what the client was claiming, thereby dramatically decreasing the income.
This resulted in a large refund for the client.
Notice of objection
Savings: $55,000
Rosen & Associates was able to reverse a clients entire CRA debt and even get them a refund. We argued that the taxpayer’s income was inflated and various expenses should have been allowed. This was accepted by the CRA. Savings of over $55,000.
Taxpayer refund
Savings: $48,000
One of our clients had been fighting hard with the CRA for over 15 years before coming to Rosen & Associates.
It took some time but we were successful in full. This work resulted in a $48,000 refund to the taxpayer.
Change of residency status
Savings: $1,385,000
After a long fought battle, Rosen & Associates was able to save our client over $1,385,000 by having him declared a non-resident of Canada for tax purposes.
Notice of objection
Savings: $116,250
Our client paid an extra $116,250 when purchasing a property. Now, because of our submission, that client will be receiving that money back in full.
Voluntary disclosure
Savings: 0% Interest/No Penalties
We were able to negotiate a 0% interest rate and no penalties over a nine year period for this client.
CRA refund
Savings: $650,000
Due to Rosen & Associates representation, our client received a refund from the CRA for over $650,000. The taxpayer was wrongly assessed as an agent acting on behalf of a foreign principal. We were able to reverse that decision resulting in a large amount of GST/HST being refunded to the client.
CRA payment plan
Savings: Structured payment plan
We assisted a client with obtaining a very favourable payment plan with the CRA. We ensured that their income would not be garnished and their home would not have a lien placed on it.
Tax court representation
Savings: $70,000
After our successful tax court representation, our client saved nearly $70,000. We were able to reverse a CRA decision on the deductibility of loans and capital cost allowance.
CRA refund
Savings: $60,000
We were able to secure our client a refund of over $60,000 by releasing ten year’s worth of child tax benefits that were wrongly being withheld by the CRA.
Taxpayer relief
Savings: $70,000
A taxpayer came to us because he was having trouble paying his tax bill due to large amounts of penalties and interest. We assisted with a taxpayer relief request.
A few months later he received relief to the tune of $70,000.
Notice of objection
Savings: $170,000
Our client, a real estate agent, was audited and her business expenses were drastically lowered. We filed a notice of objection and had the expenses allowed in full, saving her over $170,000.
Director’s liability assessment
Savings: $300,000
We were successful in reversing over $300,000 in director’s liability assessments.
Notice of objection
Savings: $100,000
We fought the CRA and successfully removed over $100,000 of taxable income for our client. The CRA agreed that the taxpayer was not a resident of Canada for tax purposes and therefore, the income earned was not taxable in Canada.