CEWS, CERS & COVID Business Subsidy Audits

I represent corporations and owner managers facing audits and reassessments of COVID 19 business supports such as CEWS, CERS and related programs. Many of these files involve more than $500,000 in alleged overpayments, plus penalties and interest.

My work includes:

• Rebuilding the revenue drop and payroll calculations period by period

• Mapping non arm’s length relationships, management companies and holding structures

• Preparing detailed responses that walk CRA through both the facts and the legislation

If CRA reassesses, I handle Notices of Objection, negotiations with Appeals, and, where necessary, appeals to the Tax Court of Canada. I’m particularly comfortable with complex arguments about control, affiliation and non arm’s length dealings.

These files often move on tight timelines. I can usually take over a matter on short notice, so you don’t miss objection or appeal deadlines while trying to make sense of CRA’s position.