We have discussed the Department of Finance’s (“Department”) proposed changes to the Tax Court of Canada Act. The Department posits that these changes will improve tax disputes between taxpayers and t...
Key Takeaways Expert credibility matters: CRA’s independent, balanced expert persuaded the Court, while the taxpayer’s conflicted expert undermined its case. Evidence must stand on its own: Expert rep...
Subsection 169(1) of the Income Tax Act (the “Act”) provides, in part, that a taxpayer may institute an appeal in the Tax Court of Canada to dispute a (re)assessment or notice of confirmation (jointly...
Section 227.1 of the Income Tax Act and section 323 of the Excise Tax Act provide that the CRA can assess corporate directors personally for a corporation’s failure to remit payroll deductions and GST...
In Bozzer v. Her Majesty the Queen (“Bozzer”), Federal Court of Appeal held that the taxpayer relief provisions contained in the Income Tax Act allow the Minister of National Revenue (“Minister”) and ...
The Minister of Finance, the Minister of Justice and the Attorney General of Canada have invited the public to comment on proposed changes to the Tax Court of Canada’s Rules.
The CRA’s Taxpayers’ Ombudsman reported that several taxpayers contacted the Taxpayers’ Ombudsman office complaining the Tax-Free Savings Account (“TFSA”) rules related to withdrawals and over-contrib...
Notices of reassessments issued by the Canada Revenue Agency (CRA) can have serious financial implications for small businesses. In 2009 and 2010, the CRA audited approximately 380,000 small and mediu...
The Canada Revenue Agency’s Voluntary Disclosure Program (the ‘‘Program’’) encourages taxpayers to voluntarily disclose unreported income. As set out in Information Circular IC00-1R2, a taxpayer who v...