In a potentially precedent-setting case, the Tax Court of Canada has determined that the often “harsh” penalties imposed on taxpayers who misreport income in two out of four years cannot be imposed if...
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 Tax Court of Canada in October last year released its reasons for judgment in Brent Kern Family Trust v. Canada [2013] T.C.J. No. 286. The case was the TCC’s first opportunity to review and apply ...
Advocate Daily initially originally published, "Tax court should go further when awarding costs”, in March 2014. Although a recent Tax Court of Canada decision shows a continued trend towards higher c...
Late last year, the Tax Court of Canada released its reasons for judgment in Ironside v. Canada [2013] T.C.J. No. 298, and Gouveia v. Canada [2013] T.C.J. No. 353. In Ironside and Gouveia, the Tax Cou...
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.
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 published various tax law blog entries related to the Canada Revenue Agency’s audit of restaurants and electronic sales suppression software (commonly referred to as “Zapper” software). The CR...
