Tax

Strategic tax counsel for business, investment, and growth.

Overview

Tax

At Gardiner Roberts, tax expertise is a core part of our practice. Our Tax Group provides practical, tailored advice to help clients achieve their business and commercial objectives in a tax-efficient manner. We combine deep technical knowledge with a results-oriented approach focused on protecting value, managing risk, and positioning clients for long-term success.

We advise on domestic and international tax planning and complex advisory mandates, often integrated with corporate, investment, real estate, finance and commercial matters. For clients with cross-border operations, we develop strategic solutions that optimize tax outcomes while managing Canadian and foreign tax exposure. We also work with international counsel and foreign tax professionals, assisting with cross-border transactions, tax treaties, capital repatriation, and tax considerations arising from the immigration or emigration of individuals and corporations.

Our boutique approach provides clients with direct access to experienced tax lawyers and advice tailored to their circumstances. As a full-service firm, we also draw seamlessly on expertise across the practice to address the legal and commercial issues that intersect with tax.

Our Tax Group advises on:

Corporate and international tax
Tax planning and transactional matters
Sales and commodity tax
Tax disputes and litigation
Charities and not-for-profit organizations
Transfer pricing and compliance
Specialized tax advisory
CRA and tax authority disputes

Expertise

We advise public and private companies, partnerships, investment funds, financial institutions, entrepreneurs and other organizations on the tax aspects of significant business decisions and transactions.

Our experience includes:

Mergers, acquisitions, reorganizations and restructurings
Domestic and international tax planning
Private equity, investment, and financing structures
Securities offerings and corporate transactions
Cross-border business and investment
Tax-efficient business structures and commercial arrangements
Tax audits, assessments, and disputes
Tax considerations arising from shareholder and partnership arrangements
Tax impact analysis in business sales, financings, license agreements, and employee stock option arrangements

We advise on the tax implications of corporate, commercial, investment, financing, and real estate transactions, helping clients structure arrangements efficiently while managing tax exposure and risk.

Our experience includes:

Tax-efficient structuring of acquisitions, dispositions, and reorganizations
Tax planning for financing, investment, and commercial arrangements
Tax due diligence and transaction structuring
Tax considerations in real estate and infrastructure transactions
Cross-border transactions and international tax planning
Tax implications of shareholder and partnership arrangements

Our lawyers advise businesses across a broad range of industries on Canadian sales, indirect and commodity tax matters, including GST/HST, provincial sales taxes, customs and duties, and taxes affecting regulated products and commodities.

We assist with:

Tax planning and business structuring
Mergers, acquisitions, and other transactions
Real estate and infrastructure projects
Cross-border activities
Financial services and emerging business models
Retail, technology, manufacturing, and other commercial operations
Audits, assessments, voluntary disclosures and appeals
HST/GST and land transfer tax issues

We represent businesses and individuals in tax audits, assessments, objections, appeals and litigation.

Our experience includes:

CRA audits, assessments and dispute representation
Notices of objection and tax appeals
Tax Court of Canada and Federal Court proceedings
GST/HST and other indirect tax disputes
International tax and transfer pricing matters
GAAR and other complex tax issues
Voluntary disclosures and compliance matters
Negotiations and settlements with tax authorities

We advise charities and not-for-profit organizations on tax planning, compliance and structuring matters, helping them navigate their tax obligations while supporting their organizational and operational objectives.

Our experience includes:

Tax considerations relating to charitable and not-for-profit structures
Advice on GST/HST and other indirect tax matters
Tax compliance and interactions with tax authorities
Structuring transactions and activities to achieve appropriate tax treatment
Tax considerations affecting donations, investments, and commercial activities
Advice on tax issues arising from organizational changes and restructuring

Advising businesses on transfer pricing and tax compliance matters, helping clients manage Canadian and international tax obligations, mitigate risk and address issues with tax authorities.

We advise on complex tax matters, including customs, insurance, HST/GST, land transfer tax and estate-related taxes, providing practical, tax-efficient solutions that manage risk and support clients’ objectives.

Representation at all levels of audits, assessments, objections, appeals and litigation, including proceedings before the CRA, Tax Court of Canada and Federal Court.