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March 31, 2011

CRA’s Related Party Initiative

Part I
By Peter Aprile
CRA’s Related Party Initiative
CRA’s Related Party Initiative
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The Canada Revenue Agency (“CRA”) is launching a new project named the Related Parties Initiative (“RPI”) aimed at wealthy individuals and related entities. The CRA intends to initiate the RPI audits sending a 22 page questionnaire to taxpayers that the CRA has selected for audit.

We recommend that taxpayers who have failed to report taxable income retain legal counsel and initiate a voluntary disclosure as soon as possible. In addition, we recommend that taxpayers who receive the RPI questionnaire retain legal counsel to assist them in providing the CRA with appropriate answers to proper CRA requests for information. Last, we recommend that taxpayers dispute any improper CRA reassessment.

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Counter Sphere 1 Image, with “CRA Reassessments Behave Like Capital Events” title text, Counter Tax Litigators LLP: strategic leadership in complex CRA disputes.

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