This article appeared in Thomson Reuters’ Tax Disputes & Resolution Centre, alongside leading resources on managing complex tax controversies.
Key Takeaways No inference of intent: Courts rejected the claim that surplus cash was earmarked for decommissioning in the absence of contemporaneous reserves, allocations, or disclosures. Rational co...
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...
Key Takeaways Forum defines outcomes: The taxpayer’s appeal was quashed without the merits ever being heard because the chosen forum lacked jurisdiction. Procedure equals substance: Courts enforce jur...
Key Takeaways Framing gap: The Tax Court accepted CRA’s framing because Vortex’s reply lacked engineering support and legal positioning. In other disputes, when claims were framed with qualified techn...
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 ...
Key Challenge: Clarifying GST/HST Supply Classification Integrated Transactions: Tax professionals should proactively evaluate whether elements of a purchase are truly independent or part of a single ...