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# Kirshen Tax Law

Experience. Expertise. Efficiency.

## Sitemaps

- [XML Sitemap](https://kirshentaxlaw.ca/sitemap.xml): Contains all public & indexable URLs for this website.

## Posts

- [Living in a Newly Built Home May Not Avoid GST/HST: Caddell v. The King](https://kirshentaxlaw.ca/caddell-gst-hst-new-home/) - In Caddell v. The King, the Tax Court found that living in a newly built home did not prevent GST/HST from applying under the self-supply rules.
- [CRA Arbitrary Assessments: What Happens When CRA Assesses Without Your Tax Return?](https://kirshentaxlaw.ca/cra-arbitrary-assessment/) - CRA can issue arbitrary assessments when a tax return has not been filed. Learn how subsection 152(7) works & what taxpayers can do to challenge an assessment.
- [Derivative Tax Liability in Canada: When You Can Become Liable for Someone Else's Tax Debt](https://kirshentaxlaw.ca/derivative-tax-liability/) - Derivative tax liability can make you responsible for another person's tax debt. Learn how section 160, director liability, & other collection provisions apply.
- [GST/HST Rebates For Those Not Registered for GST/HST](https://kirshentaxlaw.ca/gst-hst-rebate-non-registrant-2/) - Non-registrants selling real property may qualify for a GST/HST rebate under section 257, but some expenses are excluded. A Toronto tax lawyer explains.
- [Can Your Corporation Own Your Home? Shareholder Benefits Explained](https://kirshentaxlaw.ca/shareholder-benefit-corporation-home/) - Can your corporation own your home? Paying fair market rent may not prevent a taxable shareholder benefit. Learn how CRA applies the shareholder benefit rules.
- [Ordinarily Resident in Canada](https://kirshentaxlaw.ca/ordinarily-resident-canada-tax/) - Being outside Canada does not automatically end Canadian tax residency. A Toronto tax lawyer explains how the “ordinarily resident” test applies.
- [When Are Gambling Winnings Taxable in Canada?](https://kirshentaxlaw.ca/gambling-winnings-taxable-canada/) - Can gambling winnings be taxed in Canada? Learn when gambling is considered a personal activity and when CRA may treat it as a taxable business.
- [Statute-Barred Reallocation of Corporate Tax Credits](https://kirshentaxlaw.ca/statute-barred-reallocation-credit/) - CRA may deny refunds once a year is statute-barred, but corporate tax credits can sometimes be reallocated using Form RC431.
- [CRA Foreign Income Matching Letters and the Voluntary Disclosures Program](https://kirshentaxlaw.ca/cra-foreign-income-matching/) - CRA is receiving foreign financial information from countries around the world and reassessing for unreported income. Learn the risks and how the VDP can help.
- [The Two-Year Limitation Period for CRA Director Liability Assessments](https://kirshentaxlaw.ca/two-year-limitation-period-director-liability/) - CRA generally cannot assess a director more than two years after they cease being a director. Learn how the limitation period works and common disputes.
- [Voluntary Disclosure vs CRA Audit](https://kirshentaxlaw.ca/voluntary-disclosure-vs-cra-audit/) - Learn the difference between a voluntary disclosure and a CRA audit. Timing can determine whether penalties and prosecution relief remain available.
- [CRA Gross Negligence Penalty: How to Fight It](https://kirshentaxlaw.ca/cra-gross-negligence-penalty/) - Facing a CRA gross negligence penalty? Learn how these penalties apply, common CRA allegations, and how a Toronto tax lawyer can help challenge the assessment.
- [Can CRA Reassess After 3 Years? Understanding the Reassessment Period in Canada](https://kirshentaxlaw.ca/can-cra-reassess-after-3-years/) - Can CRA reassess after 3 years? Learn when the CRA can reassess beyond the normal period and how to challenge it with a Toronto tax lawyer.
- [Notice of Objection Deadline in Canada: What You Need to Know](https://kirshentaxlaw.ca/notice-of-objection-deadline-canada/) - Learn the Notice of Objection deadline in Canada and how to challenge a CRA reassessment. Speak with a Toronto tax lawyer today.
- [Intention to Pursue Profit in Canadian Tax Law](https://kirshentaxlaw.ca/intention-to-pursue-profit-canada/) - The CRA may challenge claims where an activity lacks a genuine profit motive. Learn how courts assess intention to pursue profit under Canadian tax law.
- [CRA Net Worth Audit: How to Defend Against a Reassessment](https://kirshentaxlaw.ca/cra-net-worth-audit-defence/) - Facing a CRA net worth audit reassessment? Learn how to challenge CRA assumptions and defend your position with a Toronto tax lawyer.
- [How to Become a Non-Resident of Canada for Tax Purposes](https://kirshentaxlaw.ca/become-non-resident-canada-tax/) - Learn how to become a non-resident of Canada for tax purposes. Understand CRA residency rules, common mistakes, and risks. Speak with a Toronto tax lawyer.
- [Canadian Tax Residency Determination Depends on Your Unique Facts](https://kirshentaxlaw.ca/canadian-tax-residency/) - Canadian tax residency depends on all surrounding facts and residential ties. Speak with a Toronto tax lawyer for guidance on CRA residency reviews & disputes.
- [Section 216 Elections: How Non-Residents Can Reduce Tax on Rental Income](https://kirshentaxlaw.ca/section-216-election/) - A Section 216 election allows non-residents to be taxed on net rental income instead of 25% gross withholding. Learn how it works and avoid costly CRA issues.
- [CRA Audit After Selling a House: What Triggers It and How to Respond](https://kirshentaxlaw.ca/cra-audit-after-selling-house/) - CRA audit after selling a house? Learn what triggers audits, GST/HST risks, and how a Toronto tax lawyer can help you respond and protect your position.
- [TFSA Contributions as a Non-Resident: Avoiding Costly CRA Penalties](https://kirshentaxlaw.ca/tfsa-contributions-as-a-non-resident-avoiding-costly-cra-penalties/) - Made a TFSA contribution while living abroad? Understand the CRA TFSA over-contribution tax and how a Toronto tax lawyer can help reduce penalty taxes.
- [CRA Collections Officers and Third Party Assessments](https://kirshentaxlaw.ca/cra-collections-directors-liability-unfair/) - The same CRA collections officer decides whether to assess director’s liability & section 160/325 assessments. A Toronto tax lawyer explains why that is risky.
- [Director’s Liability for Unremitted GST/HST and Payroll: The Due Diligence Defence](https://kirshentaxlaw.ca/directors-liability-due-diligence-defence/) - CRA can assess directors personally for unremitted GST/HST and payroll source deductions. Learn how the due diligence defence works and when it can succeed.
- [Employee vs. Independent Contractor in Canada](https://kirshentaxlaw.ca/employee-vs-independent-contractor-canada/) - Understand the difference between employee & independent contractor status in Canada, how the CRA makes the determination, & how a Toronto tax lawyer can help.
- [Associated Corporations and Control Rules Under the Income Tax Act](https://kirshentaxlaw.ca/associated-corporations-control/) - Understand de jure and de facto control under the Income Tax Act. Get advice from a Toronto tax lawyer on associated corporations and CRA audit exposure.
- [Received a CRA Audit Letter? Here’s What To Do](https://kirshentaxlaw.ca/received-a-cra-audit-letter-heres-what-to-do/) - Received a CRA audit letter? Here's what the letter means, how to respond, and how a Toronto tax lawyer can help protect your rights during an audit.
- [CRA Lifestyle Audits – When Your Spending Doesn’t Match Your Reported Income](https://kirshentaxlaw.ca/cra-lifestyle-audits-when-your-spending-doesnt-match-your-reported-income/) - Facing a CRA lifestyle audit? Learn how CRA compares income to spending, what triggers these audits, and how a Toronto tax lawyer can help defend you.
- [CRA Net Worth Audits: How the CRA Calculates Unreported Income](https://kirshentaxlaw.ca/toronto-tax-lawyer-cra-net-worth-audit/) - Facing a CRA net worth audit? See how the CRA calculates unreported income and how a Toronto tax lawyer can help defend you.
- [CRA Corporate GST/HST Audit Powers and How to Respond](https://kirshentaxlaw.ca/cra-corporate-gst-hst-audit-powers-canada/) - A Toronto tax lawyer explains CRA corporate GST/HST audit powers, document demands, interviews, and how to respond when your corporation is audited.
- [Beneficial Ownership in Canadian Tax Law](https://kirshentaxlaw.ca/beneficial-ownership-canadian-tax-law/) - Beneficial ownership determines who truly owns property for Canadian tax purposes. A Toronto tax lawyer explains CRA’s approach and key court decisions.
- [RRSP Over-Contributions](https://kirshentaxlaw.ca/rrsp-over-contributions-2/) - Have an RRSP over-contribution CRA is penalizing? Find out how to reduce taxes, file relief requests, & dispute the penalty with help from a Toronto tax lawyer.
- [TFSA Over-Contributions](https://kirshentaxlaw.ca/tfsa-over-contributions-2/) - Have a TFSA over-contribution CRA is penalizing? Learn how to reduce taxes, file for relief, or challenge an assessment with help from a Toronto tax lawyer.
- [Prompted vs. Unprompted Voluntary Disclosures Under CRA’s New Rules](https://kirshentaxlaw.ca/prompted-vs-unprompted-voluntary-disclosure/) - CRA now distinguishes between prompted and unprompted voluntary disclosures. A Toronto tax lawyer explains the difference and why it matters.
- [The CRA Eliminates the 90-Day Extension for Voluntary Disclosures](https://kirshentaxlaw.ca/cra-voluntary-disclosure-no-more-90-day-extension/) - A Toronto tax lawyer explains the CRA’s removal of the 90-day extension for voluntary disclosures. Call for a free consultation.
- [CRA Updates the Voluntary Disclosures Program: What Taxpayers Need to Know](https://kirshentaxlaw.ca/voluntary-disclosures-program-2025-update/) - CRA updates to the Voluntary Disclosures Program take effect October 1, 2025. A Toronto tax lawyer explains the new rules and levels of relief.
- [The CRA Voluntary Disclosure Program: Fix Tax Mistakes Before It’s Too Late](https://kirshentaxlaw.ca/toronto-tax-lawyer-cra-voluntary-disclosure-program/) - Avoid penalties, interest, and prosecution with the CRA Voluntary Disclosure Program. A Toronto tax lawyer can guide your disclosure and protect your interests.
- [How to Fight a CRA Gross Negligence Penalty](https://kirshentaxlaw.ca/gross-negligence-penalty-cra-fight/) - Facing a gross negligence penalty from the CRA? Learn how to challenge it through audits, objections, and Tax Court with a Toronto tax lawyer.
- [Gross Negligence Penalties](https://kirshentaxlaw.ca/gross-negligence-penalties-2/) - Facing a gross negligence penalty from CRA? Find out how to challenge penalties, reduce what you owe, & protect your rights with help from a Toronto tax lawyer.
- [GST/HST Audits on Property Sales](https://kirshentaxlaw.ca/gst-hst-audits-on-property-sales-2/) - Facing a CRA GST/HST audit after selling or renovating a home? See what triggers an audit, how assessments work, and how a Toronto tax lawyer can help.
- [CRA Property Flipping Audits](https://kirshentaxlaw.ca/cra-property-flipping-audits/) - Facing a CRA property flipping audit? Understand how CRA challenges home sales, what penalties apply, & how a Toronto tax lawyer can help defend your exemption.
- [CRA Penalties and Interest](https://kirshentaxlaw.ca/cra-penalties-and-interest-2/) - Owing CRA penalties and interest? Find out how to reduce tax penalties, request relief, or fight gross negligence penalties with help from a Toronto tax lawyer.
- [Exporting Vehicles and CRA Issues](https://kirshentaxlaw.ca/exporting-vehicles-and-cra-issues/) - Vehicle exporter denied ITCs by CRA? Learn how to protect your claim and respond effectively with help from a Toronto tax lawyer.
- [Substantial Renovations and the CRA](https://kirshentaxlaw.ca/substantial-renovations-and-the-cra/) - Sold a home after major renovations? Understand what counts as a substantial renovation, when GST/HST applies, and how a Toronto tax lawyer can help.
- [CRA Foreign Tax Credits](https://kirshentaxlaw.ca/cra-foreign-tax-credits/) - Denied a foreign tax credit in Canada? Find out how to respond to CRA reviews and protect your claim with guidance from a Toronto tax lawyer.
- [Unreported Income? Here’s How the CRA Responds](https://kirshentaxlaw.ca/unreported-income-heres-how-the-cra-responds-kirshen-tax-law/) - Worried about unreported income CRA might uncover? Understand how the CRA detects hidden income, what penalties apply, and how a Toronto tax lawyer can help.
- [CRA Reassessment: What It Means and How to Respond](https://kirshentaxlaw.ca/cra-reassessment/) - Received a CRA reassessment? Find out how to respond, protect your rights, and challenge unfair tax changes with guidance from a Toronto tax lawyer.
- [CRA Builder Audits: When Home Sales Trigger GST/HST Liability](https://kirshentaxlaw.ca/toronto-tax-lawyer-cra-builder-audit/) - CRA builder audits are on the rise. Learn when GST/HST applies to home sales, how CRA defines a builder, and what exemptions may protect you.
- [CRA Cryptocurrency Audits: What the CRA Knows and How to Protect Yourself](https://kirshentaxlaw.ca/how-cra-tracks-cryptocurrency/) - Learn how the CRA uncovers unreported cryptocurrency income using exchange data, blockchain analysis, and global cooperation and how to respond.
- [When Can the CRA Reassess a Statute Barred GST/HST Return](https://kirshentaxlaw.ca/statute-barred-gst-hst-reassessment/) - Can the CRA reassess your GST/HST return after the deadline? Find out when reassessments are allowed and how a Toronto tax lawyer can help defend you.
- [What to Expect from a Free Consultation with a Toronto Tax Lawyer](https://kirshentaxlaw.ca/toronto-tax-lawyer-free-consultation/) - Thinking of booking a free consultation with a Toronto tax lawyer? Here’s what to expect and how to make the most of your first meeting.
- [Selling a Self-Built Home? What Triggers CRA GST/HST Audits](https://kirshentaxlaw.ca/toronto-tax-lawyer-cra-self-built-home-gst-hst/) - Sold a self-built home you lived in? The CRA may still assess GST/HST. Learn how the personal-use exemption applies and when to call a Toronto tax lawyer.
- [CRA Releases New Guidance on Cryptocurrency Mining Activities](https://kirshentaxlaw.ca/cra-crypto-mining-guidance/) - CRA confirms that crypto mining is generally not a taxable supply for GST/HST. Learn how to classify and report crypto mining income properly.
- [T2060 Election: Deferring Tax When Dissolving a Canadian Partnership](https://kirshentaxlaw.ca/t2060-election/) - Winding up a Canadian partnership? Filing a T2060 Election may help defer tax on property distributions. A Toronto tax lawyer can guide you through the process.
- [Do You Have to Pay GST/HST on the Sale of Vacant Land?](https://kirshentaxlaw.ca/gst-hst-on-vacant-land-sales/) - We outline when the sale of vacant land is exempt from GST/HST under Schedule V, Section 9 of the Excise Tax Act, and how CRA assesses business or trade intent.
- [Is Your Business a Hobby? Applying the Pursuit of Profit Test](https://kirshentaxlaw.ca/pursuit-of-profit/) - Is your business a hobby? The pursuit of profit test can determine whether your losses are deductible. Speak with a Toronto tax lawyer today.
- [Why You May Need a Tax Lawyer to File a Notice of Objection](https://kirshentaxlaw.ca/notice-of-objection-tax-lawyer/) - Disagree with a CRA assessment or reassessment? A notice of objection tax lawyer can help challenge it & defend your rights. Speak to a Toronto tax lawyer .
- [What Is Departure Tax in Canada? Understanding the Exit Tax Rules](https://kirshentaxlaw.ca/departure-tax-canada/) - Leaving Canada? A Toronto tax lawyer explains how departure tax works, what assets are taxed, and how to defer the tax when emigrating.
- [How the CRA Taxes Cryptocurrency in Canada](https://kirshentaxlaw.ca/cryptocurrency-tax-canada/) - Understand how the CRA taxes cryptocurrency in Canada. A Toronto tax lawyer explains capital gains, mining income, audits, and voluntary disclosures.
- [Burden of Proof in Third-Party Tax Assessments: When the Onus Shifts to the CRA](https://kirshentaxlaw.ca/burden-of-proof-third-party-assessments/) - In third-party assessments under the Income Tax Act or Excise Tax Act, the burden of proof usually rests on the taxpayer. Learn when the it shifts to the CRA.
- [How to Respond to a CRA Proposal Letter Before Reassessment](https://kirshentaxlaw.ca/cra-proposal-letter-response/) - Received a CRA proposal letter? A Toronto tax lawyer explains what it means, how to respond, and why it’s your best chance to avoid a reassessment.
- [Do Non-Residents Need a Tax Lawyer in Canada?](https://kirshentaxlaw.ca/tax-lawyer-non-residents/) - Non-residents face complex Canadian tax rules. A Toronto tax lawyer can help you understand your obligations, withholding requirements, and CRA assessments.
- [Can the CRA Reassess a Statute-Barred Year?](https://kirshentaxlaw.ca/cra-reassessment-statute-barred/) - CRA can only reassess statute-barred years in limited cases. A Toronto tax lawyer explains when section 152(4) applies and how to respond to old-year audits.
- [Do I Need a Tax Lawyer or an Accountant? How to Know and Why They Often Work Together](https://kirshentaxlaw.ca/do-i-need-a-tax-lawyer-or-an-accountant/) - Accountants and tax lawyers often work together. Here’s how to know when your situation needs legal support from a Toronto tax lawyer alongside your accountant.
- [The Stages of a General Procedure Tax Court Appeal in Canada](https://kirshentaxlaw.ca/stages-of-tax-court-appeal-canada/) - A Toronto tax lawyer explains each stage of a Tax Court appeal in Canada, from the Notice of Appeal to discovery, settlement, and hearing.
- [CRA’s New Approach to Crypto – DeFi, Liquidity Pools, and Taxable Dispositions](https://kirshentaxlaw.ca/cra-crypto-defi-taxation/) - CRA considers DeFi liquidity pool transactions taxable. A Toronto tax lawyer explains how this affects you & what to do if you have unreported crypto activity.
- [Deferring Departure Tax When Leaving Canada](https://kirshentaxlaw.ca/deferring-departure-tax-canada/) - Learn how Canadian taxpayers can defer departure tax when leaving Canada, the conditions under Section 220(4.5), and when security must be provided.
- [Why Self-Employed Canadians Often Need a Tax Lawyer](https://kirshentaxlaw.ca/tax-lawyer-self-employed/) - Self-employed Canadians face unique tax challenges. A Toronto tax lawyer explains how to stay compliant, and protect your business from costly mistakes.
- [Understanding the CRA’s Room Method for Substantial Renovations](https://kirshentaxlaw.ca/cra-room-method-substantial-renovation/) - The CRA’s room method determines if a renovation meets the 90% substantial renovation threshold and triggers GST/HST. Learn more from a Toronto Tax Lawyer.
- [Do You Need a Tax Dispute Lawyer in Canada?](https://kirshentaxlaw.ca/tax-dispute-lawyer-canada/) - Disagree with the CRA? A tax dispute lawyer in Canada can help with reassessments, objections, audits, and appeals. Free consultation with a Toronto tax lawyer.
- [Section 217 Election for Non-Residents](https://kirshentaxlaw.ca/section-217-election-tax-return-canada/) - A Section 217 election allows non-residents to file a Canadian tax return on some income. Learn when it applies, filing rules, deadlines, and common risks.
- [Cryptocurrency, the Tax Court and Businesses Losses](https://kirshentaxlaw.ca/cryptocurrency-tax-loss/) - The Tax Court confirms that cryptocurrency losses caused by fraud can qualify as non-capital losses. A Toronto Tax Lawyer explains Amicarelli v The King.
- [CRA Builder Audits: GST/HST Exemptions When CRA Determines You Are a Builder](https://kirshentaxlaw.ca/cra-builder-audit-gst-hst-exemptions/) - CRA builder audits can trigger GST/HST reassessments, but important exemptions may apply. A Toronto tax lawyer explains builder exemptions under the ETA.
- [Extension Applications for Late Notices of Objection](https://kirshentaxlaw.ca/extension-application-late-notice-of-objection/) - Missed the 90-day objection deadline? CRA may still allow a late objection through an extension application. A Toronto tax lawyer explains how it works.
- [Subsection 162(7) Penalties and the Due Diligence Defence](https://kirshentaxlaw.ca/subsection-162-7-penalty/) - A Toronto tax lawyer explains subsection 162(7) penalties, how the $25-per-day penalty works, and when a due diligence defence may apply.
- [GST/HST Rebates For Those Not Registered for GST/HST](https://kirshentaxlaw.ca/gst-hst-rebate-non-registrant/) - Non-registrants selling real property may qualify for a GST/HST rebate. A Toronto tax lawyer explains what is allowed and why the rule feels unfair.
- [CRA Cryptocurrency Audit: What Triggers It and How to Respond](https://kirshentaxlaw.ca/cra-cryptocurrency-audit/) - Facing a CRA cryptocurrency audit? Learn what triggers crypto audits, data sharing risks, business vs capital treatment & how a Toronto tax lawyer can help you.
- [Life Event Exceptions to Canada’s Property Flipping Tax Rule](https://kirshentaxlaw.ca/life-event-exceptions-property-flipping-tax/) - Certain life events can exempt a home sale from Canada’s property flipping tax rule. Learn when the exception applies and how CRA evaluates these cases.
- [Capital Gains vs Business Income in Canada](https://kirshentaxlaw.ca/capital-gains-vs-business-income/) - The CRA often reassesses profits as business income instead of capital gains. Understand the risks and speak with a Toronto tax lawyer today.
- [CRA Reassessment After Audit: What To Do](https://kirshentaxlaw.ca/cra-reassessment-after-audit/) - Received a CRA reassessment after an audit? A Toronto tax lawyer explains what it means, your rights, and how to challenge the CRA effectively.

## Pages

- [Home](https://kirshentaxlaw.ca/) - Toronto tax lawyer Jeff Kirshen helps clients resolve CRA audits, tax disputes, reassessments, and other tax issues. Book your free consultation today.
- [Results](https://kirshentaxlaw.ca/results/) - CRA audit and tax dispute results by a Toronto tax lawyer, including successful objections, reversed reassessments, and significant tax refunds.
- [Voluntary Disclosure](https://kirshentaxlaw.ca/voluntary-disclosure/) - Unreported income or missed filings? Avoid CRA penalties and prosecution with help from a Toronto tax lawyer experienced in Voluntary Disclosures.
- [About](https://kirshentaxlaw.ca/about/) - Led by Toronto tax lawyer Jeff Kirshen, our firm handles CRA audits, objections, appeals, and complex tax matters. Trusted, experienced, and results-driven.
- [FAQs](https://kirshentaxlaw.ca/faqs/) - Get answers to common CRA audit and tax dispute questions. Learn how a Toronto tax lawyer can help with objections, reassessments, and voluntary disclosures.
- [NR6 Filings](https://kirshentaxlaw.ca/nr6-filings/) - Toronto tax lawyer for non-residents. We handle NR6 filings, monthly remittances, and Section 216 and NR4 compliance. Contact us for a free consultation.
- [Late Elections](https://kirshentaxlaw.ca/late-elections/) - Missed a tax election deadline? A Toronto tax lawyer can help file late elections, request CRA relief, and resolve issues with the Canada Revenue Agency.
- [Blog](https://kirshentaxlaw.ca/blog/) - Get practical insights on CRA audits, tax planning, residency, and more. Toronto tax lawyer Jeff Kirshen shares guidance to help you stay ahead of the CRA.
- [Services](https://kirshentaxlaw.ca/services/) - Explore CRA tax services from Toronto tax lawyer Jeff Kirshen. We handle audits, objections, director liability, taxpayer relief, voluntary disclosures & more.
- [Cryptocurrency](https://kirshentaxlaw.ca/cryptocurrency-tax-lawyer/) - Facing CRA crypto issues? A Toronto tax lawyer at Kirshen Tax Law can help with audits, disclosures, and crypto tax compliance. Book a free consultation today.
- [Net Worth Audits](https://kirshentaxlaw.ca/cra-net-worth-audits/) - Received a CRA net worth or lifestyle audit letter? A Toronto tax lawyer can help you challenge flawed assumptions, reduce reassessments, & protect your rights.
- [Unfiled Returns](https://kirshentaxlaw.ca/unfiled-returns/) - Behind on tax filings? A Toronto tax lawyer at Kirshen Tax Law can help file late returns, avoid CRA penalties, and respond to demands. Free consultation.
- [Taxpayer Relief](https://kirshentaxlaw.ca/taxpayer-relief/) - Facing CRA penalties and interest? A Toronto tax lawyer can help file relief requests based on hardship or errors and reduce what you owe. Free consultation.
- [Tax Residency](https://kirshentaxlaw.ca/taxresidency/) - Leaving Canada? A Toronto tax lawyer can guide you through residency severance, exit tax, and CRA compliance. Plan your departure with expert legal help.
- [Tax Planning](https://kirshentaxlaw.ca/tax-planning/) - Get strategic tax planning from a Toronto tax lawyer. We advise on income splitting, corporate structuring, and cross-border tax strategies.
- [Tax Debt](https://kirshentaxlaw.ca/tax-debt/) - Owe money to the CRA? A Toronto tax lawyer can help stop collections, reduce penalties, and negotiate tax debt relief. Contact Kirshen Tax Law today.
- [Tax Court of Canada](https://kirshentaxlaw.ca/tax-court-of-canada/) - Disputing a CRA reassessment? A Toronto tax lawyer can represent you before the Tax Court of Canada and fight to reduce tax, penalties, and interest.
- [Section 160 & 325 Assessments](https://kirshentaxlaw.ca/section-160-325-assessments/) - Received a Section 160 or 325 assessment? A Toronto tax lawyer can help defend you against CRA claims for someone else’s tax debt. Free consultation.
- [RRSP & TFSA Relief](https://kirshentaxlaw.ca/rrsp-tfsa-relief/) - Facing RRSP or TFSA over-contribution penalties? Speak with a Toronto tax lawyer about CRA relief options. Free 20-minute consultation.
- [Opinions & Memos](https://kirshentaxlaw.ca/opinions-memos/) - Need clarity on a tax issue? A Toronto tax lawyer can provide legal opinions and step memos on structuring, residency, and CRA compliance. Free consultation.
- [Notice of Objection](https://kirshentaxlaw.ca/notice-of-objection/) - Disagree with a CRA reassessment? A Toronto tax lawyer can file a Notice of Objection to challenge audits, penalties, & protect your rights. Free consultation.
- [Director’s Liability](https://kirshentaxlaw.ca/directors-liability/) - Received a CRA director’s liability letter? Get help from a Toronto tax lawyer to fight personal tax debt for payroll and GST/HST. Free consultation.
- [Criminal Tax Defence](https://kirshentaxlaw.ca/criminal-tax-defence/) - Accused of tax evasion or under CRA investigation? Speak to a Toronto tax lawyer for expert criminal tax defence. Free confidential consultation.
- [CRA Audit](https://kirshentaxlaw.ca/cra-audit/) - Received a CRA audit letter? A Toronto tax lawyer can help you respond strategically and protect your rights. Book a free consultation today.
- [Builder Audits](https://kirshentaxlaw.ca/cra-builder-audits/) - Assessed for GST/HST after selling or renovating a home? A Toronto tax lawyer can help challenge CRA builder audits and protect your rights. Free consultation.
- [Contact](https://kirshentaxlaw.ca/contact/) - Book your free consultation with a Toronto tax lawyer at Kirshen Tax Law. Get clear, trusted advice for audits, objections, tax debt, CRA disputes and more
- [Fees](https://kirshentaxlaw.ca/fees/) - Kirshen Tax Law offers free consultations, fixed fees where possible, and clear estimates. Speak with a Toronto tax lawyer for cost-effective support.

## Categories

- [Blog](https://kirshentaxlaw.ca/category/blog/)
- [Penalties](https://kirshentaxlaw.ca/category/penalties/)
- [Residency](https://kirshentaxlaw.ca/category/residency/)

## Tags

- [Disputes](https://kirshentaxlaw.ca/tag/disputes/)
- [Residency](https://kirshentaxlaw.ca/tag/residency/)
- [Tax Planning](https://kirshentaxlaw.ca/tag/tax-planning/)
- [Property](https://kirshentaxlaw.ca/tag/property/)
- [Crypto](https://kirshentaxlaw.ca/tag/crypto/)
- [Penalties](https://kirshentaxlaw.ca/tag/penalties/)
- [Audit](https://kirshentaxlaw.ca/tag/audit/)
- [Voluntary Disclosure](https://kirshentaxlaw.ca/tag/voluntary-disclosure/)