Key Points CRA can now compel sworn questioning. The Income Tax Act authorizes auditors to require oral testimony under oath during audits, bringing executives directly into the record. Early question...
Foundations
Authoritative reference chapters on Canadian tax disputes.
This article appeared in Thomson Reuters’ Tax Disputes & Resolution Centre, alongside leading resources on managing complex tax controversies.
Key Insights at a Glance Deferral as strategy: Departure tax can be deferred without interest when acceptable security is posted, preserving liquidity during transition. Forms of security: CRA accepts...
CRA audits build the first version of the dispute. Before a notice of reassessment issues, the audit process fixes factual characterizations, embeds interpretive assumptions, and narrows the range of ...
The Canada Revenue Agency’s Tax Earned by Audit (TEBA) metric tracks the gross value of tax assessed through audit activity. Although TEBA does not determine ultimate liability, it influences internal...
CRA audits establish the first durable version of an interpretive dispute. Before reassessment issues, audit interactions fix transaction characterizations, embed interpretive assumptions, and narrow ...
This article was prepared by Counter LLP’s Tax Controversy and Litigation practice, with contributions from Peter Aprile, Senior Counsel; James Roberts, Partner; and Jennifer Mak, Associate. The CRA o...
Key Takeaways for Non-Parties Declining involvement is the default, standard, and strategic approach. DoJ and CRA inquiries post-audit do not create a legal obligation to respond. Written communicatio...
You increase the odds of getting the desired outcome when you give effective discovery answers. Here are some tips to help you.
* Thomson Reuters regards the authors as individuals with expertise in tax and litigation. Thomson Reuters has published five Practical Insight chapters on different tax controversy topics, which Coun...
Resolving Tax Disputes (3rd edition) studies tax disputes, conflict levels, and basic strategies. It helps accountants to limit early-stage mistakes and reduce liability. One of the chapters in RTD3 i...
Resolving Tax Disputes (3rd edition) studies tax disputes, conflict levels, and basic strategies. It helps accountants to limit early-stage mistakes and reduce liability. One of the chapters in RTD3 i...
* Thomson Reuters regards the authors as individuals with expertise in tax and litigation. Thomson Reuters has published five Practical Insight chapters on different tax controversy topics, which Coun...
Resolving Tax Disputes (3rd edition) studies tax disputes, conflict levels, and basic strategies. It helps accountants to limit early-stage mistakes and reduce liability. One of the chapters in RTD3 i...
Resolving Tax Disputes (3rd edition) studies tax disputes, conflict levels, and basic strategies. It helps accountants to limit early-stage mistakes and reduce liability. One of the chapters in RTD3 i...
Resolving Tax Disputes (3rd edition) studies tax disputes, conflict levels, and basic strategies. It helps accountants to limit early-stage mistakes and reduce liability. One of the chapters in RTD3 i...
Resolving Tax Disputes (3rd edition) studies tax disputes, conflict levels, and basic strategies. It helps accountants to limit early-stage mistakes and reduce liability. One of the chapters in RTD3 i...
Resolving Tax Disputes (3rd edition) studies tax disputes, conflict levels, and basic strategies. It helps accountants to limit early-stage mistakes and reduce liability. One of the chapters in RTD3 i...
The general trend is that Canada Revenue Agency is disallowing more input tax credits (“ITCs”) for businesses. In addition, the CRA has launched a project to uncover and disallow ITCs they believe rel...
The CRA is imposing more penalties, including foreign reporting penalties. These penalties might, prima facie, look the same, but there are key differences. The first step in overturning these penalti...
Resolving Tax Disputes (3rd edition) studies tax disputes, conflict levels, and basic strategies. It helps accountants to limit early-stage mistakes and reduce liability. One of the chapters in RTD3 i...
*Thomson Reuters regards the authors as individuals with expertise in tax and litigation. Thomson Reuters has published five Practical Insight chapters on different tax controversy topics, which Count...
Thompson Reuters considers the authors “leading tax experts and litigators”. The authors agreed to grant TR partial rights to this work. This article first appeared in TR’s, Practical Insights in May ...
Generally speaking, taxpayers can deduct fees and costs paid to prevent a potential assessment or dispute a reassessment under paragraph 60(o)(i) of the Income Tax Act R.S.C. 1985, c. 1 (the “ITA”). W...
*Thompson Reuters considers the authors “leading tax experts and litigators”. This content first appeared in TR’s, Practical Insights in May 2020.*
*Thompson Reuters considers the authors “leading tax experts and litigators”. The authors agreed to grant TR partial rights to this work. This article first appeared in TR’s, Practical Insights in May...
*Thompson Reuters considers the authors “leading tax experts and litigators”. This content first appeared in TR’s, Practical Insights in May 2020.*
*Thompson Reuters considers the authors “leading tax experts and litigators”. The authors agreed to grant TR partial rights to this work. This article first appeared in TR’s, Practical Insights in May...
Tax disputes with the Canada Revenue Agency (CRA) present a complex challenge for individuals and businesses alike. Understanding the interplay between audit, objection, appeals, and collections proce...
The Canada Revenue Agency (“CRA”) announced, and now initiated, its 5th Annual Letter Campaign (the “Campaign”).** The CRA is in the process of sending 33,000 letters to taxpayers that have claimed bu...
In cases heard under the TCC’s general procedure (as opposed to the informal procedure), the winning party may receive more than the amount of taxes in dispute plus interest—that is, the court may awa...
We have experience representing SR&ED claimants at the objection and appeal stages. At times, we have questioned the CRA’s level of service and processes surrounding SR&ED objections. Today, the CRA p...