Key Takeaways The Tax Court’s mandate allows the DOJ and CRA to introduce new alternative theories late in litigation, which can increase cost, delay the litigation timeline, and introduce litigation ...
Key Takeaways Penn Ventilator v. HMQ shows how disputes evolve when a transaction supports two viable case theories: one tied to the structure, the other to the business’s economic behaviour. Courts r...
Key Takeaways The mechanics worked, but the Court focused on whether the reorganization produced a real economic loss or merely a paper one. That distinction shaped the GAAR outcome. The decisive batt...
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...
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...
The CRA no longer relies on blunt audit tactics to detect offshore non-compliance. It operates a layered system; data-driven, globally integrated, and increasingly predictive. Most taxpayers facing of...
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 ...