Grant Thornton’s Tax Release entitled “New rules for life insurance” does a good job of using English to explain some proposed changes to the Income Tax Act (Canada) and the Income Tax Regulations that will affect insurance policyholders. The Release…
Panama
From a CRA press release issued two days ago on the Panama papers: The Canada Revenue Agency (CRA) is committed to combating the abusive use of offshore jurisdictions and protecting the integrity of the Canadian tax system. The CRA continues…
Small business shares in RRSPs
From Daniel Gosselin, “Reversing Prohibited Status of Small Business Shares in RRSPs”, Tax for the Owner-Manager, 15:4 (October 2015): In a technical interpretation (TI 2015-0579671E5, May 28, 2015), the CRA confirms that the shares of a corporation that ceases to…
VD Data
The CRA personnel dealing with voluntary disclosures (VDs) were quite busy in fiscal 2015. Michael Friedman and Andrew Stirling, “Voluntary Disclosures Continue To Increase” Canadian Tax Highlights 24:3 (March 2016) discusses some key points found in the CRA’s report to…
US Issues in Canadian Tax Disputes
Roy Berg, in “Tax Dispute Resolution: Watch for US Issues” Canadian Tax Highlights 24:2 (February 2016), outlines some issues to consider when representing a US taxpayer who has a dispute with the CRA. He writes: The practitioner …
Jeopardy order
John Sorenson, in “Jeopardy Order Overturned” Canadian Tax Highlights 24:2 (February 2016), discusses Canada (National Revenue) v Grenon, 2015 FC 1050. In this case, the taxpayer applied to the court to overturn a jeopardy collection order made under section 225.2…
CRA Response
The CRA has responded to some Bad Press regarding the KPMG case, which I wrote about yesterday.
Secret deal for shelter participants
From the “what the hell were they thinking” file: the CBC reports that the CRA offered VD treatment (no prosecution, no penalties) to high net-worth participants in an offshore tax shelter marketed by KPMG. I wonder what change in policy…
The Shadow of the Torturer
Mr Douglas McCarthy participated in the Fiscal Arbitrators fiasco. His lawyer, as part of some pre-trial skirmishing, tried to argue, among other things, that Mr McCarthy shouldn’t have to answer questions on examinations-for-discovery because the discovery process amounts to torture.…
No bcc to clients!
Should you cc or bcc your client on an email to opposing counsel? It’s a trick question: you shouldn’t do either of these things. Instead, you should send the email to opposing counsel and then forward it to your client,…