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.
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...
* 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...
*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”. This content first appeared in TR’s, Practical Insights in May 2020.*
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