I am a partner with Morris Kepes Winters LLP. We are a law firm of tax lawyers based in Toronto.

The Ontario Alliance of Christian Schools (“OACS”) has contacted us about the recent decision by the Canada Revenue Agency (“CRA”) to reassess charitable donations made to the CEAF Student Support Program (“the Program”).

The OACS tells us the CRA has reassessed or will reassess some or all donors to the Program. The CRA is denying these donors’ tax credit. This means the donors will not get a tax credit for donations they make, or have made, to the Program.

We understand that donors may not have hired a lawyer to appeal the CRA’s reassessment. Our law firm, Morris Kepes Winters LLP, has extensive experience representing large groups of taxpayers in such tax appeals. We are offering to act as the lawyers for each of the donors the CRA reassesses.

Hiring one law firm to represent a group keeps costs down. Legal fees are shared among a large number of people. The group of donors do not have to shoulder all of the fees themselves.

We understand you participated in the Program. Our firm is offering to act as your lawyers on the tax appeal.

If you agree to retain us, we will act as lawyers only for you and for any other reassessed donors who choose to hire us. We do not act for the OACS. We are independent from the OACS. The OACS has chosen to recommend our firm. It has kindly forwarded this letter to you, to start the process.

Two important points:

  1. If you would like to hire our firm, you must carefully read the Retainer Agreement accompanying this letter. This includes the document Some Questions You May Have and Some Answers, included below. Make sure you understand everything. Follow the instructions to complete the Retainer Agreement. Once you fill it out, and return it to us, signed and initialled, and with a retainer cheque and the information we ask for, we will be your lawyers. Until you complete every step and meet every requirement, we are not your lawyers, and you have not retained us to act for you in this matter.
  2. Time is of the essence. There is a deadline for you to file a Notice of Objection to the CRA reassessment. It is 90 days from the date on your Notice of Reassessment. Morris Kepes Winters will need time from the day you retain us and give us all your information, to get your Notice of Objection filed. If you wish to retain us, we must have your completed Retainer Agreement and retainer cheque no later than September 30, 2013.

If you do not send a completed Retainer Agreement and retainer cheque to us by September 30, 2013, that will mean you have chosen not to retain us. We will not be your lawyers. You will not be entitled to the benefit of our services.

If you do choose not retain us, you ought to consider retaining your own lawyer to represent you in the dispute with the CRA.

Yours very truly,

Robert Kepes