Savoy Now Somewhat Shabby
Voluntary disclosure legal fees
Access to information
PWC has just published a good Tax Memo (2012-27) on taxpayer access to audit and appeals reports and other documents generated by the CRA in the course of issuing a reassessment. I found helpful the references to P-148 and CRA technical interpretation 2011-0403751C6 regarding what the CRA should provide without the taxpayer having to make an access request.
Involuntary VD
Objecting Too Early
Lawyers! Again.
I wrote about whether an officer or director of a corporation could represent it in a Tax Court appeal in a post I wrote about White Star Copper Mines Limited v R, 2007 TCC 669. A more recent decision appears to deviate from the approach taken in White Star.
ABIL
Garron dismissed
A victim of fraud
I found it impossible not to feel sorry for Mr Ruff, a lawyer who paid hundreds of thousands of dollars to a team of fraudsters: see Ruff v R, 2012 TCC 105. Naturally, the CRA disallowed his attempt to deduct the losses as business expenses. The Tax Court agreed with the Minister’s position.