The Strategic Choice After Reassessment
Comparing the CRA’s self-adjudication stage with independent oversight in appeal
Insights
Key Takeaways Richard Homburg claimed a deduction that would have cut the tax on his $1.16 million stock option benefit in half. The CRA said his control and influence over the company meant Homburg...
Bill C-31 gives the CRA more power and a greater advantage in tax disputes. At audit, it adds a notice of non-compliance with daily penalties and suspends the reassessment period while a notice is...
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Key Takeaways The result was fixed before Chobham Corporation Ltd. filed its Notice of Appeal. In many cases, the Tax Court can overturn a reassessment; this was not that kind of case. Internal...
A tax opinion answers a narrower question than most readers assume. Some of the limits are written into the document — in its assumptions, its scope section, its definitions paragraph, and its date....
A tax plan is moving toward implementation. The tax opinion has been delivered. The first question is whether the filing position is defensible. A tax opinion may answer that question and stop...
A company receives a CRA reassessment after prior planning work and tax opinions supported the transactions or filing positions. The company believes the core risk has already been addressed. The...