Revocation

The following is an extract from a press release posted on the CRA’s website today:

The Canada Revenue Agency (CRA) has revoked the registered charity status of the Francis Jude Wilson Foundation, a Montreal-area charity. This revocation was effective February 23, 2008, and follows a letter dated August 27, 2007, that was sent to the Foundation.

Notes on a Price Adjustment Clause

The following article will appear in the next edition of the HLA Journal.

Almost every tax-driven reorganization requires the lawyer implementing it to draft a price adjustment clause (a “PAC”). Most lawyers will have their favourite precedent for such a clause, but a lawyer needs to understand the nature and purpose of PACs—and how the CRA interprets them—so that he or she can use them appropriately in the context of any given set of transactions. This article does not purport to be a complete review of the theory and practice of PACs; it is more like a collection of notes on some of the more important features of a PAC precedent.

Requirements

The following article appeared in the latest edition of the HLA Journal.

CRA “requirements” (a “Requirement”) are a form of garnishment for unpaid taxes, and they can be quite troublesome for a business, especially if its systems aren’t what they should be. Businesses are used to acting as tax collectors for the federal and provincial government, of course: businesses withhold and remit amounts from wages and they collect and remit sales taxes. A Requirement, however, applies whenever a business is liable to pay an amount to another person; it is an obligation to act as a tax collector that applies in a broader variet of circumstances, not just when wages are payable, or goods or services are sold.