Objections Tips and Tricks

I’ve written a short article that provides some tips and tricks for preparing a notice of objection.

2024 STEP Roundtable

The following is based on the text published in Tax Topics 2713 (September 10, 2024). Question 1 – Spousal Trusts A spousal trust that receives a contribution of capital after the death of the spouse-beneficiary remains a spousal trust, but…

Appeal quashed

In Cole v R, 2024 TCC 64, [1] The Appellant spent the better part of ten years trying to convince the Minister of National Revenue to remove over $240,000 added to her taxable income for the 2011 taxation year. Due…

Demands for information from non-residents

Canada (National Revenue) v. Schreiber, 2024 FC 729, the Federal Court held that, in general, the CRA is entitled to demand information from non-resident persons or entities.

Dissolved trust year-end

At the 2024 CALU conference round table (question 12, addressed in 2024-1005851C6), the CRA confirmed that a bare trust has a December 31 year-end and that a trust (other than a GRE) that dissolves during a calendar year still has…

Reassessment outside the normal reassessment period

In Cheema v R, 2024 TCC 81, the Court held that the CRA was entitled to reassess beyond the normal reassessment period where the taxpayer provided no good explanation for a disposition of real property he did not report or…

2024 STEP Roundtable

Appeal quashed

Demands for information from non-residents

Canada (National Revenue) v. Schreiber, 2024 FC 729, the Federal Court held that, in general, the CRA is entitled to demand information from non-resident persons or entities.

Demands for information from non-residents

Canada (National Revenue) v. Schreiber, 2024 FC 729, the Federal Court held that, in general, the CRA is entitled to demand information from non-resident persons or entities.

Dissolved trust year-end

Reassessment outside the normal reassessment period