The CRA has published an updated version of Information Circular IC00-1 (IC00-1R3 Voluntary Disclosure Program).
Over there
Offshore is in the news again. I wonder whether these studies confuse offshore accounts with tax evasion, at least to some degree. Canadian law doesn’t prevent one from keeping money in a tax haven bank account provided the existence of…
Coming soon to a taxpayer near you
In “Soliciting VDs?“, I wrote about the CRA’s “letter campaign”, which is supposed to “to inform taxpayers about their tax obligations and to encourage them to correct any inaccuracies in their past income tax and benefit returns.” The campaign continues,…
Questions for the CRA
I will be co-chairing the CRA Tax Administration Panel on the second day of the CTF Ontario Conference (on Tuesday, October 30). If you have any burning questions for the CRA that you’d like to have answered, please send them…
ATIP problems
The Taxpayers’ Ombudsman has released a report on the CRA access to information program (“ATIP”). The report reads in part as follows:
Soliciting VDs?
Several clients of a colleague of mine have received letters from the CRA requesting that the taxpayers make a disclosure to the CRA if they happen to find unspecified errors in their tax returns.
Tax protesters redux (ridiculous more like)
The CRA is warning Canadians to stay away from the tax protest movement, again. I can’t believe people are still falling for this crap given that, as the CRA release points out, “Canadian courts have repeatedly and consistently rejected all…
CRA News
The CRA issued a couple of interesting technical interpretations in the last few months. Foreign Entity Classification The CRA will no longer issue technical interpretations on foreign entity classification (CRA technical dated August 04, 2011, 2011-0415141E5) because whether the foreign…
Non-share Corporations for Cottages?
Some practitioners have suggested that it might be possible to use a non-share corporation to own a family cottage. Query, however, whether the CRA would assess a benefit to a member of a corporation who used its cottage and didn’t…
10-Year Limitation for Relief Revisited
In 2005, I wrote a post about the 10-year limitation period for relief applications that was introduced by the 2004 budget, and I noted that the drafting of the limitation period was ambiguous. The Federal Court of Appeal just released a decision resolving that ambiguity in favour of the taxpayer given the purpose and context of the relief provisions: see Bozzer v. The Queen, 2011 FCA 186, rev’g 2010 FC 139.