This morning, I spoke at an Ontario Bar Association seminar entitled “More Tax Issues You Cannot Afford to Miss”. My subject was professional corporations. You can download a copy of the paper that I co-authored on the subject here.
CRA Obligations to Disclose Audit Files
In Scott Slipp Nissan Ltd. v. Canada (Attorney General), 2005 FC 1477, the Federal Court held that section 295 of the Excise Tax Act did not authorize the Minister to refuse to disclose portions of an audit report merely because…
“Grumbling”?
I sit on the executive of the Ontario Bar Association’s tax section. In that capacity, I gave an interview to the London Free Press yesterday about proposed amendments to the Ontario Business Corporations Act. The amendments will allow professional corporations…
Limits on Fairness
Apparently, the Department of Finance and the CRA believe that you can have too much fairness in the tax system. In the 2004 budget, Finance introduced a ten-year limitation period for fairness applications. It appears that the CRA is now adopting a particularly strict interpretation of the rule to deny relief to taxpayers even where the events that form the basis for the fairness request occurred within the limitation period.
CRA Alert Service
The CRA has launched an “alert service” to provide information on tax shelters, “scams” and other areas of interest. Will the service make it easier for us to provide advice to our clients?
Tax Cases of Interest
On Thursday, November 3, I will be presenting at the CRA’s quarterly Tax Practitioner’s Consultation Group meeting at the Royal Botanical Gardens. In my presentation, I will discuss recent “Tax Cases of Interest” including the Supreme Court of Canada decisions…
Real Estate and Tax
Joe Monaco and I will do a presentation for the Realtors Association of Hamilton-Burlington tomorrow on real estate and tax. You can obtain a copy of our PowerPoint presentation here.
OBA Presentation on Charities
I will present at a seminar hosted by the Charity and Not-for-Profit section of the Ontario Bar Association in Toronto on Wednesday, October 26. I will cover topics addressed in my article on the new split-receipt rules ((2004) 18(4) The…
Supreme Court Releases GAAR Decisions
The Supreme Court of Canada, in Canada Trustco Mortgage Co. v. The Queen, 2005 SCC 54 and Mathew v. The Queen, 2005 SCC 55, released its first judgments on the general anti-avoidance rule yesterday. The Court unanimously dismissed the Crown’s…
More on CRA Demands for Information
Redeemer Foundation v. M.N.R., 2005 FC 1361, represents an interesting coda to my article on CRA demands for third-party information. In this decision, the Federal Court quashed reassessments that were based on information obtained pursuant to an improper demand for third-party information.