Voluntary Disclosures & Judicial Review: 3 steps critical to submissions & victory

Canadian Tax Insights S01E02 (2017)
Voluntary Disclosures & Judicial Review: 3 steps critical to submissions & victory
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Summary
CPD

Canadian Tax Insights, Season 1 Episode 2 is designed to provide accountants with actionable takeaways (and some free verifiable CPD). 

In this episode, Peter Aprile and Yoni Moussadji provide an overview and takeaways to help accountants and taxpayers better understand and challenge Canada Revenue Agency decisions that improperly deny taxpayer applications under the Taxpayer Relief Program and Voluntary Disclosures Program.  In particular, Peter and Yoni discuss how accountants and taxpayers can ensure complete submissions, and how first-level and second-level submissions can increase or decrease taxpayers’ probability of success at the judicial review stage. 

Enjoy!

Peter Aprile

Presenter

Peter Aprile, Counter Tax Lawyers

Peter Aprile is a senior lawyer specializing in tax dispute resolution and litigation. His vision as Counter’s founder and his everyday role at the firm are one and the same: to be an agent of change, uncovering opportunities and developing strategies that achieve more than anyone expected. A creative thinker, Peter studies problems from all different angles to find what others have missed. He’s also convinced that he likes winning more than most people.

Different people describe Peter in different ways. At the CRA and the federal Department of Justice, the word relentless comes up quite a lot. Admittedly, so does the word a**hole – but it’s often said with a certain grudging respect, if not affection. Peter’s clients call him a saint. Well, some of them, anyway. His colleagues describe him as empowering and harddriving, but fair. Peter’s friends call him loyal. His wife describes him as a lot to deal with, but worth it. Peter encourages his young daughter and son to call him “The Big Homie,” though with limited success. His mother describes him with the single word mischievous – before going on to complain that he should call more.

Read Peter’s complete bio →

Insights

Leveraged growth leads to CRA reassessments and disputes. This insight explains how exposure modelling, objection strategy, and dispute readiness affect a company’s ability to reduce or overturn a reassessment.

Counter Sphere 1 Image, with “CRA Reassessments Behave Like Capital Events” title text, Counter Tax Litigators LLP: strategic leadership in complex CRA disputes.

CRA’s audit architecture drives reassessments that behave like capital market shocks inside private companies. This article examines the structural forces at play and how executives maintain control once CRA formalizes its position.