Valuation related tax disputes can arise when the Canada Revenue Agency (CRA) challenges the value ascribed to a company’s or individual’s shares pursuant to tax reorganizations.  Often these disputes hinge on the allocation of value among multiple share classes with differing rights and restrictions, or the allocation of value among multiple shareholders.  The value of an individual’s estate at the time of death, and the resulting tax liability may also be a source of dispute between the estate and the CRA, or among the estate’s beneficiaries.

CHS has extensive experience providing expert valuation services for matters brought before the Tax Court of Canada and understands the CRA’s evolving positions on how different share attributes and structures can impact value.