I came across an interesting (older) technical interpretation a few days ago while looking at another matter. In TI 2009-0338911E5, the CRA commented on the rules in section 80 of the Income Tax Act applicable to a CCPC that was winding-up voluntarily where, as a result of the winding-up, debt owed in equal amounts to the 50/50 shareholders of the corporation would be forgiven.
Thoughts on things cross border
Please see this post for an interesting perspective on some of the 2014 Budget’s cross-border measures by my colleague, Jonathan Garbutt of Garbutt Tax Law. In addition, the Tax Lawyers Alliance, Garbutt Tax Law and EMG Transfer Pricing Experts are…
PAC news
From the CRA “Income Tax Technical Publications” email list: “Income Tax Folio Chapter S4-F3-C1: Price Adjustment Clauses has been updated along with its Chapter History page. The effective date of the update is January 14, 2014.”
Depression
“‘Natural Person’ Tax Evasion Theory Caused ‘Staggering Losses’ At CRA: Report” For some reason, this story depresses me.
Objections and Taxpayer Relief
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…
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.
New T1135
In the headlines today: the “Harper Government announces new requirements for Canadians with offshore property and income”. Accountants have been waiting for this announcement in fear and trembling. The added work at tax time will not be insignificant.
Paying whistleblowers
The CRA has traditionally not offered rewards to whistleblowers, and so it is not surprising that they “missed out” recently on a chance to obtain information on possible tax cheats. Of course, the policy has now changed. It’d be interesting…
Pendulum swing
Redeemer Foundation v Canada (National Revenue), 2008 SCC 46, makes it clear that the CRA has broad powers to demand information relating to unnamed third parties, sometimes even without the need for prior judicial authorization (as per subsection 231.2(2)). Two…
The Search for Revenue
The trend continues. The CBC made a big deal (and rightly so) out of a disclosure of a huge amount of data on offshore bank accounts made to the director of the International Consortium of Investigative Journalists. It appears that German tax authorities have purchased a CD containing information on deposits made to Swiss bank accounts. The authorities purchased the data for €4 million but they expect to recover €500 million in taxes using the data. That’s a pretty good return on their investment (even taking into account the collections costs).