The Minister and the CRA have, in some circumstances, attempted to disregard the common law. We have been waiting for the CRA to announce its response to the Bozzer decision.
Today, the CRA distributed a news release entitled Taxpayer relief deadline is December 31, 2011. This news release confirms that the CRA will follow the Federal Court of Appeal’s decision in Bozzer. In addition, the CRA announced that it will adopt this change for requests for taxpayer relief made under the Air Travellers Security Charge Act, Softwood Lumber Products Export Charge Act and the Excise Act.
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CRA’s TEBA-driven audits surge near March 31, often leading to disputes. Understanding the CRA’s metrics, forces, and patterns helps businesses anticipate risk and prepare strategically.
A CRA audit isn’t just a process – it’s a conflict, unfolding in real-time. We created a CRA In-Audit Escalation Framework to reduce and avoid CRA audit risks.
CRA’s scrutiny of offshore assets and T1135s is increasing. Proactive dispute planning helps taxpayers control risk, optimize outcomes, and avoid costly reassessments.
The Enns v. Canada decision clarifies 'spouse' under section 160 of the Income Tax Act, impacting RRSP and TFSA estate planning. Jennifer Mak, along with other expert tax lawyers on our team, breaks down key insights.
Discover the benefits of fully engaging or strategically disengaging from CRA's internal objection process. Explore expert insights for favourable results.
Peter Aprile is a very hands on and practical tax lawyer who is very focused and diligent. He is a pleasure to work with.
- Susan Farina, Tax Partner, Price Waterhouse Coopers
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