Simplifying The Resolution Of Tax Disputes In Canada

Canada has a world-class tax dispute system. For the most part, participants engage in the process in good faith, act with integrity, and treat all parties with fairness. We shouldn't forget this. But our tax dispute process can and should be simplied.

In this article, we present several recommendations for reform. We expect that these measures would enhance eciency and speed the resolution of tax disputes while protecting the broader integrity of the tax system.

Background

Canada's self-assessing tax system is a "pay and chase" model: the CRA processes taxpayers' returns, conrms taxpayers' lings, collects amounts owing, and refunds overpayments. Then the agency reviews and audits selected taxpayer les. If reassessments are issued, the CRA's Appeals Branch may be called on to resolve any disputes through an administrative process. All of this happens before a matter reaches court.