CRA’s Related Party Initiative

Part I

0:44

The Canada Revenue Agency (“CRA”) is launching a new project named the Related Parties Initiative (“RPI”) aimed at wealthy individuals and related entities. The CRA intends to initiate the RPI audits sending a 22 page questionnaire to taxpayers that the CRA has selected for audit.

We recommend that taxpayers who have failed to report taxable income retain legal counsel and initiate a voluntary disclosure as soon as possible. In addition, we recommend that taxpayers who receive the RPI questionnaire retain legal counsel to assist them in providing the CRA with appropriate answers to proper CRA requests for information. Last, we recommend that taxpayers dispute any improper CRA reassessment.

For additional analysis, see our Insights.

Insights

CRA Reassessment After a Tax Opinion | Tax disputes move beyond the original filing position

A CRA reassessment tests something different from the original tax opinion.

CRA Settlement After a Reassessment: When Resolution Becomes Unstable | Zhang v. HMK illustrates how resolution may not be treated as final inside the institution

Tax Court of Canada decision on CRA settlement after reassessment, showing how accepted settlement terms may not end the dispute when CRA and DOJ continue pulling the file back. (Zhang v HMK)

A CRA reassessment and dispute do not start from a neutral position. They shape the dispute, now and later. This article explains how the record develops and the impact on teh range of outcomes.

Notice of Objection Failed to Define the Dispute | Some objection-stage failures are obvious. Others remain invisible and lead to the same result. (941624 Alberta Ltd. v. HMK)

CRA reassessment and notice of objection. Large corporation regime. How a failure to define the dispute can stop an appeal early or narrow what can be argued later.

Notice of Objection Window | What Carries Forward | What is placed on the objection record here is not neutral

Filing a Notice of Objection places part of the dispute on the record before it is treated as final. That record shapes how the matter is assessed and what can still be changed.

CRA Dispute Record Formation | Decisions Made Before Clarity

Decisions made after a CRA reassessment form the dispute record before they are recognized as final. That record shapes what can be said, changed, and defended later.

Explore more insights >

Related Insights

CRA’s Related Party Initiative

Insights