Litigation Management & Support

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DRTP Consulting’s tax litigation services are relevant to any business that needs to analyze and document specific transactions for tax purposes. Tax audit activities and litigation have substantially increased in Canada recently. More than ever before, state-of-the-art expertise is required to address tax litigation issues without compromising on the reputation of the enterprise.

The best line of defence through the audit and appeal processes remains well-built arguments based on the facts and circumstances of the case to meet the transparency and clarity threshold required by tax administrations. This is where DRTP Consulting brings its tax, accounting and economics expertise to bear.

 


 

Transfer pricing and international tax

  • CRA and IRS audits / tax litigation management
    • Consulting, strategic planning and analysis
    • Documentation assembly and case building
    • Transfer pricing economic studies
    • Negotiations with tax authorities
  • Requests to the Appeals divisions
  • CRA and IRS objection and appeal processes
    • Consulting, strategic planning and analysis
    • Documentation assembly and case building
    • Transfer pricing economic studies
    • Negotiations with tax authorities
  • Voluntary disclosures
  • Competent Authority processes
    • Double tax relief consulting
    • Mutual agreement procedure
    • Treaty-based requests, returns and waivers
  • Transfer pricing economic expert-witness for tax litigation
  • Economic studies and database searches

 

Treaty-based requests, returns and waivers / International transactions issues

Numerous related matters may arise from or independently from transfer pricing. DRTP Consulting provides services on treaty-based requests, returns and waivers as well as international tax and trade issues, including:

  • Non-resident Canadian income tax matters
  • Residency matters
  • Permanent establishment matters
  • Transfer pricing adjustments
  • Double taxation of income from real property or business profits
  • Tax withheld on dividends, interests, royalties, management fees, services provided by non-residents, income from real property
  • Issues on income from interest or related to capital gains
  • Double taxation arising from employment income, pension and annuities
  • Part XIII Tax withholding under the Canadian Income Tax Act
  • Regulations 102 and 105 withholding waivers
  • Double taxation on other types of income
  • Foreign tax credit matters
  • Negotiation and litigation support related to antidumping disputes
  • Customs valuation audits and litigation support

 

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