What is the Sham Transaction Doctrine?
The "sham transaction" doctrine is a legal concept that has been created by the courts to apply to circumstances where a taxpayer attempts to disguise a transaction to make it appear to be something…
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CRA Collection Powers and Restrictions
Pursuant to section 225.1 of the Income Tax Act (“ITA“), the Canada Revenue Agency (“CRA“) can only begin taking action to collect taxes owed to it (including interest and penalties) after…
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The CRA is auditing taxpayers for “advantages” received from a “registered plan strip” relating to investments made with John Scholz, Northland Capital Inc., and Red Hill Capital Inc.
Understanding CRA Audits on Registered Plan…
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In Canada, government decision-making bodies have decision-making powers that can significantly affect individuals’ and businesses’ rights and interests. As a result, there is a need to ensure that administrative bodies make their decisions…
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Situations where the CRA Performs a Net Worth Audit
In situations where the Canada Revenue Agency (“CRA“) suspects that a taxpayer has earned more income than reported on their tax returns, the CRA can perform what is known as a “net…
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Powers of the CRA
The Minister of National Revenue (“Minister“) is responsible for administering and enforcing Canadian tax laws. In practice, however, the Canada Revenue Agency (“CRA“) performs nearly all of the Minister’s functions…
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Gross Negligence Penalties
Once the Canada Revenue Agency (“CRA“) audits a taxpayer and comes to the conclusion that the taxpayer made false claims or under-reported their taxes, the CRA can apply additional penalties known as “gross…
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What is the CEWS Program?
The Canada Emergency Wage Subsidy (“CEWS”) is a wage subsidy program provided to qualifying employers who have seen a drop in revenue due to COVID-19. If you are eligible for the CEWS program, you will receive…
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What is Tax Evasion
Tax evasion is when a taxpayer intentionally evade Canadian tax laws to avoid paying their tax liability. Tax evasion can be done in many ways, for example, by purposely not reporting income, falsifying records, or inflating…
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Debts Owed to the CRA Vs. Other Creditors
Owing a debt to the Canada Revenue Agency (“CRA“) is not like any other debt. Unlike other creditors, the CRA has powerful and broad powers under the law that it can use to collect its debt owed…
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Interest and Penalties
The Canada Revenue Agency (“CRA“) charges taxpayers who fail to pay their tax debts on time daily compounded interest on their outstanding tax debts. The CRA can also charge taxpayers penalties for filing their…
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The Canada Revenue Agency’s (“CRA“) Voluntary Disclosures Program (“VDP“) is a program administered by the CRA that allows Canadian taxpayers to voluntarily come forward and declare previously undeclared income or to correct past…
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Sham Transaction Doctrine
CRA Jeopardy Orders
Audits of Registered Plan Strips (John Scholz)
Federal Court: Judicial Review of CRA Discretionary Decisions
CRA Net Worth Audits
Taxpayer Bill of Rights
CRA Gross Negligence Penalties
Canada Emergency Wage Subsidy Audits
Tax Evasion
CRA Collection Powers
Taxpayer Relief Program
The CRA Voluntary Disclosures Program