Canadian Tax Law: Tax Opinions
Neufeld Legal Professional Corporation
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Tax Opinions



Optimizing opportunities provided by Canada's tax laws.

When devising and implementing complicated financial and tax structures, it is strongly recommended that a qualifying tax opinion be obtained on both the specific facts of the particular situation and the current tax laws and regulations relative thereto. For whereas the goal of your tax and financial planners (together with your internal corporate leadership) are driven by the realization of the optimal profit output, such an approach needs to be reviewed and assessed by experienced legal counsel.

For the lawyer is intended to provide an assessment of Canada's taxation laws and regulations relative to the intended financial pursuit and render their qualified legal opinion thereof, with the additional provision of guidance that would place the proposed structure in better position relative the Canada Revenue Agency. This is the objective goal of the law firm with respect to rendering a tax opinion, which have a very broad range of possibilities, given the variety of tax limiting business structures that companies seek to pursue.*

The range of Tax Opinions includes, but is not limited to:

  • General Anti-Avoidance Rule (GAAR) tax opinion

  • Harmonized Sales Tax / Goods & Services Tax (HST/GST) tax opinion

  • Transfer Pricing tax opinion

  • Income Tax legal opinion

  • Withholding Tax legal opinion (cross-border transactions)

  • Corporate transaction tax opinion (mergers & acquisitions)

  • Tax Shelter legal opinion

  • Investment tax opinion

  • International tax treaty legal opinion

  • Natural Resources (oil & gas) tax opinion

As such, when your company or your investment strategy requires that you attain a tax opinion to support your tax minimization strategies (as opposed to impermissible tax avoidance),** contact tax lawyer Christopher Neufeld at 403-400-4092 (Calgary, Alberta) / 416-887-9702 (Toronto, Ontario) or

* The reality however remains that even a lawyer's legal tax opinion is but an interpretation of the law, with the final determinant being the Tax Court, which alone has the power to rule on the legitimacy of a particular tax structure or business result. In turn, neither a lawyer nor the Canada Revenue Agency (CRA) can provide you or your company with a definitive position on the outcome of a taxable action.

** We render legal opinions that are consistent with the law, such that your business strategy must be brought into conformity with relevant laws and regulations, failing which the legal tax opinion that we render may very well be rendered inapplicable in relation to your tax-related activities. The law is the law and it is a legal requirement that you conform with both the letter and the spirit of the law.

NOT LEGAL ADVICE. Information made available on this website in any form is for information purposes only. It is not, and should not be taken as legal advice. You should not rely upon, or take or fail to take any action, based upon this information. Never disregard professional legal advice or delay in seeking legal advice because of something you have read on this website. The law firm of Neufeld Legal PC would be pleased to discuss legal matters referenced in this website upon their retention in accordance with applicable requirements pertaining to client retention by this law firm.


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Tax Lawyer Christopher Neufeld with the business law firm of Neufeld Legal Professional Corporation, is admitted to practice law in Alberta and Ontario (Canada) and New York State (United States of America).  Christopher's legal practice focuses primarily on business law, in particular corporate commercial transactions and contract work  - directed at transactional tax optimization and effective tax planning. The content of this website is purely for informational purposes and should not be relied upon - as you should consult a lawyer with respect to the specifics of your particular legal matter.  Please review our legal disclaimer and privacy policy prior to contacting us and be advised that contacting us does not create a lawyer-client relationship. National headquarters: 1600, 144 - 4th Avenue SW, Calgary, Alberta. COPYRIGHT 2010-13.

Business Tax Planning: Corporate Tax Planning; Multi-Jurisdiction Tax Planning; Offshore Tax Planning; Business Succession Planning; Tax Loss Planning / Utilization
Personal Tax Planning:
Individual Tax Planning; High Wealth Tax Management; Family Succession Planning; Estate & Gift Taxation; Non-Canadian Tax Planning

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