$1.7M for CRA’s “Malicious Prosecution” Set Aside on Appeal
The British Columbia Court of Appeal (the “BCCA”) reversed (the “Decision”) a landmark decision (the “Lower Court Decision”) that had awarded a B.C. couple… Read more
Tag: Taxpayer Representation & Litigation
Bribery and Corruption in International Business
The SNC-Lavalin affair has dominated the Canadian news media for two months without complete revelation of what really happened. All that we know for… Read more
Fines and Penalties
Section 67.6: “In computing income, no deduction shall be made in respect of any amount that is a fine or penalty (other than a… Read more
CRA’s Initial Cryptocurrency Audits are Likely First of Many
The Canada Revenue Agency (the “CRA”) appears to be targeting users of bitcoin and other cryptocurrencies for audit, according to a Forbes online article… Read more
Paradise Papers, New VDP Not Government’s Panacea in 2019
The Canada Revenue Agency (the “CRA”) has launched roughly 100 audits into taxpayers named in the Paradise Papers offshore tax leak, according to documents… Read more
CRA Crackdown Eyes Toronto and Vancouver Property Sales: Worth $600 Million in Lost Revenue
The CRA is focussed on recovering lost revenue in the real estate market. In particular, it is targeting home sales in Vancouver and Toronto…. Read more
Uber’s Tax Woes Signal Gig Economy is the Next Frontier in CRA’s Tax Collection Efforts
Uber wants its users, its drivers and particularly the Canada Revenue Agency (the “CRA”) to agree that it does not provide “rides” to its… Read more
Restaurant Owners Who Buy from The Beer Store Will Face Increased CRA Scrutiny
Ontario restaurant and bar owners are likely the latest target of the Canada Revenue Agency’s (the “CRA”) effort to audit unreported or under-reported income… Read more
The Three Steps of GAAR
Please see Vern Krishna’s latest article for the Taxnet Pro: Tax Disputes & Resolution Centre titled, “The Three Steps of GAAR” where he discusses the… Read more
A Review of Rectification in a Post-Fairmont World
Please see David Piccolo’s latest article for the September issue of the Tax Advocate titled, “A Review of Rectification in a Post-Fairmont World,” where he… Read more
