Privilege

The Minister of Finance has apparently responded positively to submissions from the Canadian Bar Association on the effect of the new reporting regime for tax avoidance transactions on solicitor-client privilege. In a letter to the Association dated January 11, 2011,…

Justice

It’s hard educating clients about the tax system and what they’re up against when disputing assessments. Clients will often complain not just about the assessments they are fighting but the attitude of the auditor, the delays caused by the CRA and the unfairness inherent in a tax system that only a very few understand really well. The taxpayers in Lauger v. The Queen, 2007 TCC 650, brought these complaints to Tax Court with them and asked the Court to do the Right Thing. To which the Court, in dismissing the appeals, responded “I must decide whether the assessments are well-founded or not”.