Montreal, Quebec, Canada
Lawyer and founder of Valerie Messore Law, I represent Canadians and their businesses in tax litigation using my skills and knowledge gained from a decade of representing the CRA in a wide variety of tax cases. My mission is to empower taxpayers in the exercise of their rights and resolve the tax issue that burdens them, so that they can go back to pursuing the things in life that are important to them. My vision is to build a trusting relationship with my clients who know I have their best interests at heart and feel confident throughout the process of resolving their dispute. An advocate at all levels of tax disputes, I will: - Make persuasive representations to the tax authorities in response to audit queries. - Object to adjustments that have been reassessed. - Put my client's best case forward in litigation before the Tax Court of Canada, Federal Courts, and Quebec Courts. - Identify grounds and applying for relief from interest and penalties. Learn more at www.valeriemessore.ca.
Representing Canadians and their businesses in tax litigation, using skills and knowledge gained from a decade of representing the CRA in a wide variety of tax cases. I provide client-centered legal services to make clients feel confident throughout the dispute resolution or litigation process. An advocate at all levels of tax disputes: • Making persuasive representations to the tax authorities in response to audit queries. • Objecting to adjustments that have been reassessed. • Putting my client’s best case forward in litigation before the Tax Court of Canada, Federal Courts, and Quebec Courts. • Identifying grounds and applying for relief from interest and penalties.
Represented the CRA in tax litigation. Counsel on tax cases covering a wide variety of issues, such as investment tax credits, deductibility of interest expense, and international tax cases.
Tax Litigation & Dispute Resolution Advised both SMEs and large corporations during tax audits, made representations at the objection stage, counsel on litigation proceedings.
Represented the Canada Revenue Agency in cases before the Tax Court of Canada, the Federal Court, the Federal Court of Appeal and the Superior Court of Quebec. Selection of Reported Cases Ludmer v Attorney General of Canada, 2018 QCCS 3381: Plaintiffs claimed $117 million in damages related to the conduct of the CRA in the course of its audit of their interests in an offshore investment vehicle. The Court awarded less than $5 million. Stewart v The Queen, 2018 TCC 75 (appealed to FCA): The Court allowed our motion to strike the partnership’s members’ notices of appeal on the grounds of abuse of process by relitigation. The partnership had filed a notice of discontinuance resulting in a deemed dismissal of its appeal, which is a final judgment. Ferlaino v The Queen, 2017 FCA 105: The Court agreed with our calculation of employment benefits from stock options denominated in USD. The amount paid for the shares was to be converted to Canadian dollars on exercise date. Korfage v The Queen, 2016 TCC 105: The Court agreed that the appellant’s deduction for the amount of his pension income that is exempt from Canadian tax pursuant to the Canada-US Tax Treaty arises on a monthly basis, when each pension benefit payment is received by the appellant. Hypercube v The Queen, 2015 TCC 65: The Court agreed that the software development work done by the appellant did not meet the definition of SR&ED because there was no technological advancement. Bouchard v The Queen, 2013 TCC 247: The Court agreed that the appellant did not have a source of income against which to deduct expenses. His intention in founding a partnership to fund his daughter’s tennis expenses was personal in nature and it was not operated in a commercial manner.