Crypto Tax Litigation & Appeals
When a CRA audit escalates into reassessment or dispute, effective tax litigation requires not just courtroom experience — but a deep understanding of how crypto transactions, valuations, and cross-border structures actually work. At Solstice Law, we represent clients in crypto-related tax disputes at all stages of the appeals and litigation process, from CRA objections to hearings before the Tax Court of Canada.
Our Approach
We combine technical tax-law expertise with crypto-native fluency, allowing us to identify procedural weaknesses, evidentiary gaps, and valuation inconsistencies in CRA’s positions. Our goal is to resolve disputes efficiently and strategically, using every available administrative and judicial avenue before full trial becomes necessary.
Our Expertise
CRA objections and appeals – Preparing detailed Notices of Objection, coordinating valuation and accounting evidence, and engaging with CRA Appeals Division to negotiate early resolution.
Evidentiary and procedural strategy – Building strong factual records, expert reports, and documentary trails that withstand CRA scrutiny and judicial review.
Penalty and gross-negligence defense – Challenging assessments involving negligence, misrepresentation, or deliberate non-compliance with nuanced, fact-driven arguments.
Cross-border and multi-jurisdictional litigation – Coordinating with foreign counsel to address related audits or investigations arising in the U.S., EU, or offshore jurisdictions.
Collaborative, Tax-Driven Advocacy
Our litigation approach is multidisciplinary and data-driven — working with accountants, blockchain forensics teams, and valuation experts to translate complex crypto histories into clear, defensible tax positions. We prioritize outcomes that minimize client exposure while preserving long-term compliance integrity.
Why Clients Choose Solstice Law
Clients turn to us because we are one of the only Canadian firms combining deep tax-dispute experience with crypto-industry specialization. Whether defending against a multi-million-dollar reassessment or appealing a complex GST/HST ruling, we bring strategic insight, procedural precision, and crypto-specific expertise to every stage of the litigation process.