During the COVID-19 pandemic, over 340,000 Canadian businesses received the Canada Emergency Wage Subsidy (CEWS), with businesses receiving around $100 billion in financial support from the Canadian government.
Currently, the Canada Revenue…
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On July 6, 2023, the Canada Revenue Agency (CRA) announced new administrative guidance concerning revised mandatory disclosure rules included in the Income Tax Act (ITA), via the Budget Implementation Act (Bill C-47). Developed in consultation…
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The world of tax law often seems daunting for many individuals and businesses. Consequently, when disputes with the Canada Revenue Agency (CRA) arise, it becomes crucial to grasp your rights and understand the litigation process. Hence, this…
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The Book of Documents (BOD) is a crucial part of the Tax Court of Canada Procedure. Serving as a comprehensive record of all evidence presented by both the taxpayer and the Canada Revenue Agency (CRA) in a given tax dispute, it is indispensable…
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The Tax Court of Canada serves as an independent judicial body that handles tax-related cases, primarily disputes between taxpayers and the Canada Revenue Agency (CRA).
Filing an Appeal
When a taxpayer disputes a CRA decision, the first…
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CRA's Initiatives: Leads Program
The CRA’s Leads Program enables individuals to report businesses, charities or individuals of tax or benefit cheating in Canada.
Examples of domestic tax cheating includes:
A Canadian business…
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Under Subsection 152(7) of the Income Tax Act (ITA), and subsection 299(1) of the Excise Tax Act (ETA), the Minister of National Revenue isn't bound to accept information or returns from a taxpayer while determining their assessment.
If…
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The Federal Court of Appeal (FCA) case, Khanna v. The Queen, 2022 FCA 84, greatly impacts the gross-negligence penalties under subsection 163(2) of the Income Tax Act (ITA). Two key points emerge from this case. Firstly, for the imposition…
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Sections 230 and 230.1 of the Income Tax Act (“ITA”) set out taxpayers’ requirements to keep adequate books of account and records for tax purposes. Section 230(1) requires every person carrying on business or required to pay or…
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Statutory interpretation is the process by which courts interpret and apply the law that is written in statutes. One of the challenges of interpreting a statute is that words often have more than one single meaning. Another challenge of…
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Understanding Tax Avoidance and Tax Evasion
It is a principle of tax law that taxpayers are entitled to arrange their affairs to minimize the amount of taxes they are required to pay. On this basis, the law differentiates between tax “evasion”…
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The Income Tax Act (“ITA”) imposes certain investment restrictions on registered plans. Registered plans are only allowed to invest in property that is considered a “qualified investment.” These plans are also not allowed to invest…
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Canada Emergency Wage Subsidy (“CEWS”) Audits
Canada Revenue Agency Unveils Mandatory Disclosure Rules Guidance
Tax Litigation in Canada: What You Need to Know
Tax Court of Canada Procedure: Understanding the Book of Documents
Tax Court of Canada – Procedure & Process Guide
CRA Leads Program: Reporting Tax and Benefit Cheats
How to Challenge a CRA Net Worth Audit
Khanna v. The Queen: A FCA Case on Tax Gross Negligence Penalties
CRA Record Keeping Requirements
Statutory Interpretation in Tax law
Application of General Anti-Avoidance Rule (GAAR) to Tax Planning
Investment Restrictions on Registered Plans