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...
In its first decision on third party penalties, the Tax Court of Canada has curtailed the power of the Canada Revenue Agency; as expected, the CRA has already decided to appeal.
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...
Prior to 1999, the Minister of National Revenue and Canada Revenue Agency (hereinafter jointly referred to as the “CRA”) had two legislative tools to severely punish taxpayers, advisors, planners, pro...
The Canada Revenue Agency (“CRA”) has assessed a number of taxpayers who have participated in the detax schemes. In addition, the CRA has imposed 50% subsection 163(2) gross negligence penalties. We t...
We have written several postings related to the proposed changes in the Tax Court Act and Tax Court Rules. To review, the proposed changes seek to increase the Tax Court Informal Procedure Limits (i.e...
The Canada Revenue Agency Appeals Branch provided our firm with the following statistics related to the number of tax dispute and tax litigation files along with the rates of settlement, withdrawal an...
The Department of Finance (Finance) has released a document entitled Consultation Regarding the Impact of Contingency Fees on the Effectiveness of the Scientific Research & Experimental Development Ta...
Subparagraph 60(o)(i) of the Income Tax Act (ITA) allows a taxpayer to deduct legal fees paid to contest an assessment of tax, interest or penalties including, but not limited to, fees incurred to pro...