The following is from an interesting article on mondaq.com by a couple of lawyers at Gowlings: The CRA recently announced a new pilot project allowing CRA appeals officers to consider applications for interest and penalty relief concurrently with notices of…
Kossow appeal dismissed
Apparently, the Federal Court of Appeal has dismissed the taxpayer’s appeal of Kossow v R, 2012 TCC 325. I say “apparently” because the decision was reportedly posted to the Federal Court of Appeal’s website and then taken down rather quickly.
Collections While a Reassessment is Under Objection
Can the CRA force a taxpayer to provide information about net worth and the location and identity of assets for the purposes of assessing the “credit risk” of a debt owing pursuant to an assessment when that assessment is under…
More tax in the news
Is it me, or is tax attracting more attention in the news lately (like over the last two or three years)? Here’s an article on tax and corporate finance.
CRA information flow
The OBA tax section sponsored a good session today on “Best Practices for Managing the Flow of Information to and from the Canada Revenue Agency”. A couple of interesting tidbits that came out: 1. Some folks at the CRA seem…
Family Law Again
The Ontario Court of Appeal has considered again whether property that was supposedly the subject of a gift should be excluded from a husband’s net family property for the purposes of the Family Law Act (Ontario): see Buttar v Buttar,…
Illegally obtained evidence
Can the CRA use evidence it has obtained (arguably) illegally using its civil audit powers in the course of a criminal investigation in reassessing a taxpayer for civil purposes? I would have thought that the answer was ‘yes’, and the…
Date of mailing a reassessment
Ordinarily, when confronted with an allegation that a notice of reassessment was not mailed on the date printed on the notice, the CRA will respond with affidavit evidence from a CRA officer. The affidavit will state that the CRA invariably…
Klundert loses again … and again
It appears Mr Klundert, about whom I wrote previously here, is not having any further luck in his court battles. The CRA reassessed him for unpaid taxes in respect of income he failed to declare and for which he was convicted on evasion charges. His appeal of the related civil reassessments to the Tax Court (Klundert v R, 2013 TCC 208) was dismissed recently because, among other things, the Court found the appeal to be an abuse of process.
Fighting tax avoidance
This BBC story on fighting tax avoidance by multinationals is rather short on substance. No doubt the Devil will be in the details.