2025 World Tax guide | Regional profile (Tax Controversy)

Deloitte Legal Canada LLP (Deloitte Legal Canada) is a national law firm founded over 16 years ago. As an affiliate of Deloitte, Deloitte Legal Canada has access to Deloitte’s global network of subject specialists and advisers in supporting clients and has the privilege of providing legal counsel to many of the world’s largest companies. Deloitte Legal* operates in 75+ geographies, our 2,500+ legal professionals collaborate seamlessly across borders and with other Deloitte businesses and service lines.

Deloitte Legal Canada addresses challenges with comprehensive thinking powered by experience and insights drawn from diverse business disciplines, industries, and global perspectives. We bring together legal advice, strategy, and technology to develop innovative solutions and create value for our clients and their businesses.

*“Deloitte Legal” means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal and regulatory reasons, not all member firms provide legal services.

Our team advises clients at all stages of the dispute resolution process, including international income tax disputes, customs disputes, and various provincial tax matters, where we provide representation at all court levels. Our firm also offers support on cross-border tax issues. In parallel to our ever-growing Tax practice, Deloitte Legal Canada has launched an Employment and Labor Law practice and a Data Privacy and Cybersecurity law practice, both in 2019.

As part of the Deloitte organization, which has collected several technology-related accolades and has a strong track record in providing technology solutions, both through in-house capabilities and alliances with technology companies, we combine legal skills with innovative service delivery, and intelligent data analysis to find the right solutions for our clients.

Deloitte Legal Canada has access to industry specialists and a wide range of professional services spanning strategy, finance, human capital, risk, technology, audit, tax, and, of course, legal, to help tackle the most complex business problems. Our internal cross-business collaboration facilitates the development of end-to-end solutions for clients.

Our tax litigation and controversy services include advice and representation with respect to the following:

• Management of large and complex tax audits and dealing with audit queries and formal requirements to provide information and documents. 
• Administrative appeals to tax authorities and litigation before the courts, including:
  - Preparation of notices of objection to dispute tax assessments or reassessments
  - Appeals to the Tax Court of Canada, Federal Court of Appeal, and the Supreme Court of Canada
  - Applications for judicial review of administrative decisions or omissions of the tax authorities
• Obtaining rectification orders from the provincial courts.
• Making voluntary disclosures to correct deficiencies in non-compliance; and
• Advising on tax risks related to transactions, including risks relating to the General Anti Avoidance Rules (GAAR).

Awards

• ITR World Tax guide 2024 | Jurisdiction ranking: Deloitte Canada was one of the member firms recognized in the Americas region (tier 1).
  Source: International Tax Review
• ITR World Tax guide 2024 | Tax Controversy Leaders: Nine Deloitte professionals were recognized: Patrick Bilodeau (Ottawa), Mike Collinge (Toronto), Olivier Fournier (Montreal), Richard Garland (Toronto), Norma Kraay (Toronto), Markus Navikenas (Calgary), Rob O’Connor (Toronto), Christine Ramsay (Toronto), and Joel Scheuerman (Calgary).
• ITR World Tax guide 2024 |Women in Tax Leaders: Norma Kraay (Toronto) and Christine Ramsay (Toronto).
  Source: International Tax Review
• ITR Americas Tax Awards 2023: Christine Ramsay was recognized as the North America Transfer Pricing Practice Leader of the Year
  Source: International Tax Review
• The Best Lawyers in CanadaTD | 2023 edition: One Deloitte Legal Canada professional was recognized: Olivier Fournier (Montreal).
  Source: The Best Lawyers in CanadaTD
• The Best Lawyers in CanadaTD | 2024 edition: Five Deloitte Legal Canada professionals were recognized: Olivier Fournier (Montreal) and Joyce Lee, K.C. (Vancouver). Ones to Watch: Adèle Desgagné (Calgary), Aicha Nafii (Montreal), and Lauzanne Bernard Normand (Montreal)
  Source: The Best Lawyers in CanadaTD
• 2023 Chambers Canada Guide: Deloitte Legal Canada was ranked in the Chambers Canada Guide.
  Source: Chambers and Partners
• 2024 Chambers Canada Guide: Deloitte Legal Canada was ranked in the Chambers Canada Guide.
  Source: Chambers and Partners
• 2023 Chambers Canada Guide: Olivier Fournier (Montreal) was recognized as one of Canada’s leading tax litigators.
  Source: Chambers and PartnerS
• 2024 Chambers Canada Guide: Olivier Fournier (Montreal) was recognized as one of Canada’s leading tax litigators.
  Source: Chambers and Partners
• 2023 Legal 500: Deloitte Legal Canada’s Tax practice was ranked in the Legal 500 Canada Guide.
  Source: Legal 500
• 2024 Legal 500: Deloitte Legal Canada’s Tax practice was ranked in the Legal 500 Canada Guide.
  Source: Legal 500
• Lexpert: Olivier Fournier and Joel Scheuerman are featured leading lawyers in the Canadian Legal Lexpert Directory, as consistently recommended in the area of Litigation—Corporate Tax. Olivier Fournier was also included as a Lexpert-ranked lawyer in the 2021 Lexpert Special Edition on Canada’s Leading Litigation Lawyers.
  Source: Lexpert

Eminent leaders

• Mike Collinge
• Olivier Fournier
• Joel Scheuerman

^{This document has been prepared solely for the purpose of publishing in the 2025 ITR World Tax guide and may not be used for any other purpose. This document and its contents may not be reproduced, redistributed, or passed on, directly or indirectly, to any other person in whole or in part without Deloitte’s prior written consent.}

^{Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities (collectively, the “Deloitte organization”). DTTL (also referred to as “Deloitte Global”) and each of its member firms and related entities are legally separate and independent entities, which cannot obligate or bind each other in respect of third parties. DTTL and each DTTL member firm and related entity is liable only for its own acts and omissions, and not those of each other. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more.}

^{This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms or their related entities (collectively, the “Deloitte organization”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser.}

^{No representations, warranties or undertakings (express or implied) are given as to the accuracy or completeness of the information in this communication, and none of DTTL, its member firms, related entities, employees or agents shall be liable or responsible for any loss or damage whatsoever arising directly or indirectly in connection with any person relying on this communication. DTTL and each of its member firms, and their related entities, are legally separate and independent entities.}

^{© 2024. For information, contact Deloitte Global.}