Tax

Our tax valuation professionals have a combined 50+ years of experience working in and leading the CRA Toronto Regional Valuations Section. Also having occupied senior roles in tax dispute services within large international financial advisory firms, they are uniquely positioned to provide impartial and complete analyses and understanding of tax-related valuations.

Our team’s valuation opinions and analyses are timely, well-reasoned, informed and cost effective and allow our clients the advantage of practical insight. We maintain relationships with several of Canada’s leading law firms and have assisted in managing all valuation-related aspects of the tax dispute process, settlement negotiations, mediation/arbitration, and providing expert witness evidence before the Tax Court of Canada.

Our clients include privately-held and publicly-traded companies across a broad industry spectrum as well as individual shareholders requiring fair market value determinations as required under Income Tax Act:

Multi-national and Cross-Border Issues: We provide experienced valuation analysis in relation to issues including the measurement of real property and intangible assets in relation to determining Taxable Canadian Property; the valuation of intellectual property assets in support of corporation reorganizations; valuation analysis in support of transfer pricing issues; and consideration of related party debt issuances and market interest rates.

Closely-Held Companies: Analyses of early-stage pre-revenue companies to large privately-held multi-nationals. We have experience in analyzing commercial goodwill; risks of operational reliance on key customers, suppliers and management; cash flow projections for early-stage companies; and consideration of special purchaser premiums, economic value-added and synergies.

Shareholder-Related Valuation Issues: Our professionals take steps to utilize relevant company-specific analysis in completing any valuation of Employee Stock Option Plans; restricted share agreements and related vesting metrics; share re-issuance on forgiveness of debt; and discount analysis relating to minority interests and marketability.

Estate and Trust Valuation Issues: We deal in valuation and financial issues arising from the establishment / dissolution of estates and trusts.

Tax Dispute Resolution Services: Out team provides effective review, analysis and rebuttal of Audit valuation queries and proposed assessments; independent consideration of the strengths and weaknesses of any valuation-related Notices of Assessment for Board or Audit Committee purposes; tax reserve determinations as required for financial reporting; and assistance to counsel regarding and proposed settlement discussions and expert witness reports and testimony.

Key Contacts