Tax Dispute Resolution

Introduction

SGA Tax: Your Partner in Complex Tax Disputes

Tax disputes present financial, regulatory, and governance challenges that require informed technical judgment. Audits, reassessments, penalty disputes, and appeals often involve interpretation of legislation, evidentiary analysis, and procedural strategy. SGA Tax provides tax dispute resolution services led by Chartered Professional Accountants and tax specialists with experience across CRA audit, objection, and appeals divisions. Our work focuses on position analysis, documentation support, technical interpretation, and structured engagement with tax authorities to manage financial exposure and protect client interests.

Increased enforcement activity by the Canada Revenue Agency has expanded scrutiny of income reporting, GST/HST compliance, capital gains treatment, and cross-border disclosures. Unresolved disputes may result in penalties, interest accruals, cash-flow strain, or reputational impact. SGA Tax assists clients through each phase of the dispute lifecycle, from audit response through resolution discussions, ensuring that tax positions remain technically supportable while limiting financial disruption.

Many disputes arise from filing errors, incomplete documentation, or inconsistent interpretation of tax rules. Others involve more complex matters such as transfer pricing adjustments, denied credits, or treaty application issues. Assumptions that audits resolve informally or that appeals guarantee relief frequently lead to adverse outcomes. SGA Tax applies legislative analysis under the Income Tax Act, Excise Tax Act, CPP and GST/HST frameworks to clarify issues, correct deficiencies, and pursue proportionate resolutions through negotiation or formal objection where warranted.