Tax Disputes & Compliance Remediation
A letter from the tax authority, a missed filing from a past year, or a form you realize hasn't been filed in years — each has a formal route to fix it, and the earlier you act, the more options you usually have. We represent clients in CRA and IRS queries and audits, and work through voluntary disclosure, late filing and penalty relief to put things right by the book, rather than letting them escalate.
Who this is for
- Individuals and businesses who have received a CRA or IRS letter, review notice or audit request
- Taxpayers who have found unreported foreign assets or income in prior years and want to come forward
- Departed or overseas residents who haven't filed a T1 or 1040 for several years and need to catch up
- U.S. taxpayers with delinquent FBAR, 5471 or 3520 filings who are worried about penalties
- Parties who disagree with an assessment and are considering an objection or appeal
- Taxpayers who missed a filing or payment for a reasonable cause and want to seek penalty relief
What we cover
Letters & audit response
- Responding to CRA and IRS letters, review notices and requests for information
- Organizing records, preparing positions and representing in personal and corporate audits
- Handling targeted reviews such as net-worth assessments and remittance reviews
- Responding to and negotiating at the proposal (proposed adjustment) stage
Voluntary disclosure & catch-up filing
- Canadian Voluntary Disclosures Program (VDP) eligibility assessment and application
- U.S. Streamlined Foreign Offshore compliance procedures
- Catch-up filing of multiple years of late T1 / 1040 returns
- Remediation path for delinquent FBAR accounts
Penalty relief
- Canadian taxpayer relief applications: discretionary relief of interest and penalties
- U.S. reasonable-cause arguments and first-time penalty abatement
- Relief claims for late-filing, late-payment and information-return penalties
- Preparing the statement of facts and supporting documents for relief applications
Objections, appeals & targeted remediation
- Filing and presenting a Canadian Notice of Objection
- Representation through the reconsideration and appeal stages of a disputed assessment
- Non-resident remediation: reasonable-cause statements for late 5471 / 3520 filings
- An overall review of multiple historical years and a one-time wind-down plan
How we work
- 01
Assess the position
We first establish whether you face a query, an audit or a historical omission, which years and taxes are involved, and which remediation routes are still open.
- 02
Choose the route
Between voluntary disclosure, catch-up filing, objection and relief, we pick the soundest procedure given the eligibility rules and deadlines, and explain what each one means.
- 03
Prepare & submit
We organize the workpapers and statement of facts, prepare the catch-up returns or applications, and file with the CRA or IRS and follow up on the correspondence.
- 04
Review & close out
A CPA reviews the key positions before filing; we follow the authority's response through to closure and set up arrangements to stay compliant afterward.
Frequently asked
I got a CRA letter asking for information. Should I just reply myself?
First understand what the letter is: some are routine reviews asking for backup documents; others are audits or proposed adjustments with bigger consequences. What you say and how you say it affects where things go next, and an over-broad or inaccurate reply can sometimes widen the issue. It's worth confirming which year and what kind of adjustment the letter concerns before deciding how to respond, and having us correspond on your behalf where needed.
I have some past-year foreign accounts I never reported. Will I be penalized if I file now?
Coming forward voluntarily is usually better than being found. Programs like Canada's VDP and the U.S. Streamlined procedures can relieve some penalties when applied for while you still qualify and before the authority has contacted you about it. Whether they apply, and how much relief follows, depends on whether the omission was non-wilful, the years involved and the specific program. Timing is key — once the authority reaches you first, those routes may no longer be open.
I left Canada years ago and haven't filed since. Do I need to catch up?
If you still had a Canadian filing obligation in those years, or didn't complete a final return when you departed, you generally need to catch up. Filing isn't only about meeting the obligation — it's often a prerequisite for claiming benefits, obtaining clearance, or returning later. With multiple years involved, filing in the right order and reflecting the residency change matters, so it's worth assessing your specific obligations before you begin.
The penalty has already been assessed. Is there still a way to reduce it?
There may be. Canada's taxpayer relief and the U.S. reasonable-cause defence allow you to seek relief of interest or penalties where the default was due to a reasonable cause such as illness, disaster or reliance on incorrect professional advice; the U.S. also offers first-time abatement to those who qualify. Relief isn't automatic — it has to be applied for with a statement of facts and support — and the outcome depends on whether the cause holds up, so it's best to claim early.
I never filed Form 5471 / 3520 and I'm several years late. How do I fix it?
The late-filing penalties on these information returns can be significant, but there are remediation paths. Where the authority hasn't already pursued you, you can usually attach a reasonable-cause statement to the catch-up filing, asserting the omission was non-wilful and explaining why; those who qualify can also handle it through programs such as Streamlined. Whether relief follows depends on the facts and the route chosen, so it's worth clarifying which years and forms are involved before closing it all out.
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Book a consultThis page is general information and not tax advice — for your specific situation, please book a consultation.
