Legal Letter to CRA

LEGAL LETTER TO CRA

This Legal Letter to the Canada Revenue Agency (CRA) is prepared and transmitted by the parties identified below for the purpose of asserting positions, requesting relief, and authorizing representation in respect of the tax matters described herein. Taxpayer Name: Business Number or Social Insurance Number: Tax Year(s) / Fiscal Period(s):

Taxpayer Address: Represented by: Representative Firm: Representative Contact (phone/email):

Date of Letter:

RECITALS

WHEREAS the Taxpayer is subject to one or more assessments, reassessments, or administrative determinations issued by the CRA related to the tax years or fiscal periods identified above; and

WHEREAS the Representative has been engaged by the Taxpayer and is authorized by the Taxpayer to communicate with and receive information from the CRA on the Taxpayer's behalf in accordance with the scope described in this letter; and

WHEREAS the parties wish to set out the scope of authority, requested relief, supporting facts, and the legal understandings governing the representation and communications to the CRA.

NOW THEREFORE, in consideration of the mutual covenants and agreements contained herein, the parties agree as follows:

1. AUTHORITY TO REPRESENT

The Taxpayer hereby appoints and authorizes the Representative to act as the Taxpayer's authorized representative before the CRA for the matters identified in this letter. The Representative is authorized to receive and inspect confidential taxpayer information, correspondence, notices of assessment or reassessment, and to make submissions, file objections, request relief, and negotiate with the CRA on behalf of the Taxpayer to the extent necessary to pursue the relief described in Section 4.

The Taxpayer certifies that the Representative is authorized to access the Taxpayer's tax accounts and to sign and submit documents on the Taxpayer's behalf to the CRA, unless a more limited authority is specified in writing below. Limited authority (if any):

2. SCOPE OF REPRESENTATION

The Representative's authority under this letter is limited to the tax matters and periods identified above and to the specific requests for relief set out in Section 4. The Representative shall not enter into any settlement or waive substantive rights without the Taxpayer's prior written consent.

3. STATEMENT OF FACTS

The Taxpayer sets out the following facts as the basis for the requested position and relief. The facts stated below are true, complete, and accurate to the best of the Taxpayer's knowledge and belief.

4. RELIEF REQUESTED

The Taxpayer requests that the CRA take the following actions (check all that apply and provide particulars where requested):

Reassessment or amended assessment in favour of the Taxpayer

Waiver or cancellation of penalties

Relief or suspension of interest

Filing of a formal objection on the Taxpayer's behalf

Voluntary disclosure submission / request for administrative relief

5. SUPPORTING DOCUMENTS

The following documents are provided in support of the Taxpayer's position. The Representative is authorized to submit copies of these documents to the CRA on the Taxpayer's behalf.

Financial statements and schedules

Contracts, agreements, and invoices

Correspondence with CRA and third parties

Legal or accounting opinions

6. UNDERTAKINGS AND CERTIFICATIONS

The Taxpayer represents and warrants that the facts set out in this letter and in the supporting documents are true, complete and accurate to the best of the Taxpayer's knowledge and belief. The Taxpayer acknowledges that making a false statement for the purpose of obtaining tax relief may constitute an offence and may attract administrative penalties and criminal liability.

The Taxpayer further undertakes to notify the Representative and the CRA promptly of any change in the facts or circumstances relevant to this matter, and to provide any additional documents or information reasonably requested by the CRA in connection with the matters addressed in this letter.

7. CONFIDENTIALITY AND DISCLOSURE

All communications between the Taxpayer and the Representative relating to the representation are subject to solicitor-client or professional privilege where applicable. The Taxpayer expressly authorizes disclosure of relevant information to the CRA and acknowledges that such disclosure may be necessary to pursue the requested relief.

8. NOTICES

Any notice or communication required or permitted under this letter shall be in writing and delivered to the addresses set out below. Notices delivered by mail are deemed given five business days after posting; notices delivered by electronic mail are deemed given on transmission if sent during business hours on a business day, otherwise on the next business day.

9. GOVERNING LAW

This letter shall be governed by and construed in accordance with the laws of the Province or Territory of , and the laws of Canada applicable therein.

10. ENTIRE AGREEMENT

This letter constitutes the entire agreement between the parties with respect to the subject matter hereof and supersedes all prior agreements, understandings, and communications, whether written or oral, regarding the matters set out in this letter.

11. SEVERABILITY

If any provision of this letter is held to be invalid, illegal or unenforceable in any respect, the validity, legality and enforceability of the remaining provisions shall not in any way be affected or impaired.

12. AMENDMENT AND WAIVER

No amendment, modification or waiver of any provision of this letter shall be effective unless in writing and signed by both parties. No failure or delay by either party in exercising any right hereunder shall operate as a waiver of that right.

13. COUNTERPARTS

This letter may be executed in counterparts, each of which shall be deemed an original and all of which together shall constitute one and the same instrument. Signatures sent by electronic transmission shall be effective as original signatures.

14. CERTIFICATION

By signing below the Taxpayer certifies that they have the authority to retain the Representative and to authorize the disclosures and actions described in this letter. The Representative certifies that they are duly authorized and qualified to act on behalf of the Taxpayer in communications with the CRA.

Sign Now