I’ve just published a permanent page to my blog on voluntary disclosures.
Form of notice
In Suffolk v. The Queen, 2010 TCC 295 (an informal procedure case), the Court undertook an interesting review of the caselaw relating to the validity of notices of assessment that contain errors and the form required for a valid notice…
DIY Prescribed Rate
The Income Tax Act in numerous places requires interest to be paid, either by the taxpayer or the Minister, on certain overdue amounts. The rate applicable is computed by reference to the “prescribed rate”. The Act also provides for calculating certain kinds of benefits by reference to that same rate. The rate fluctuates each calendar quarter. Usually, the CRA publishes the rate on its website well in advance of each quarter. For some reason, however, the CRA has still not published the rate for 2010 Q3. What is a poor tax adviser to do?
White collar
The CRA is huffing and puffing to reassure Canadians “that the minority of tax preparers and promoters who try to make money at the expense of Canadian taxpayers are not getting away with it”. Granted, my experience does not represent…
Audit headlines
It’s not often that a CRA audit makes headlines: Canada Revenue probe focuses on some RBC DS clients.
Zapper
The CRA is attempting to hunt down store owners who install software that “suppresses” records of cash sales made through a cash register. Maybe that’s an argument for making a voluntary disclosure now. Visit the taxman before he visits you.
Valuation redux
In a post I wrote about a year ago, I complained about the CRA’s then-recent pronouncements on control premiums. The CRA, at the most recent Canadian Tax Foundation BC Conference, recanted this position, at least in part, as follows:
Civil penalties
The so-called “civil penalties” in section 163.2 of the Income Tax Act (Canada) have been with us since 2000. We learned today that the CRA has imposed the penalties in 24 cases to date and that it is considering whether…
Nightmare
Unfortunately, with the experience I have working with the CRA, it is only too easy for me to imagine how this might happen: ‘Revenue Canada refuses to pay for million-dollar mistake‘. Wow.
Corrupt
No doubt some taxpayers believe that the CRA is corrupt, but the truth is that most CRA personnel are dedicated and professional civil servants. On the other hand, it’s not necessarily lily-white either.