CRA Price Adjustment Clauses Update
The following article appeared in the June, 2014, issue of the Hamilton Law Association HLA Journal.
Lawyers who must draft price adjustment clauses (“PACs”) will want to read Income Tax Folio S4-F3-C1 (the ‘Folio’), which the CRA has issued and updated recently to replace the venerable Interpretation Bulletin IT-169. The following article discusses some of the Folio’s highlights.
Local interest
163(1) Due Diligence
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A Warning from the Court
The following article on the tax preparer penalties appeared in a recent issue of the HLA Journal.
The “third-party civil penalties” in the Income Tax Act (the “Act”) have been with us for some time now. When they were first introduced, they caused some consternation because they made tax advisers potentially liable with their clients for penalties for misstatements on tax returns. In my experience, these penalties have had the effect Finance was looking for when it introduced the penalties: most of the accountants with whom I deal are quite cautious when it comes to circumstances that might involve the application of the penalties. Perhaps they would be cautious anyway, but it is a rare discussion about a questionable or aggressive filing position for which a client is advocating where the accountant does not mention these penalties.