News and Media

Tax Views: Appealing tax assessments a long and expensive journey

21st September 2017

Taxpayer appeals to the Canada Revenue Agency (CRA) are the first step in resolving tax disputes following an assessment for taxes. The procedures are strictly controlled, the timelines are stringent and subject to technical issues of delivery of documents. 

There are three principal steps for resolving income tax disputes with the CRA. The first is to file a proper Notice of Objection. Although the mechanics of this step are fairly simple (identify the taxpayer, the assessment objected to, the years involved, and the reasons for the objection), it is important to set out the relevant provisions, and a brief statement of the reasons for the department to review. The scope of the Objection can become an issue in subsequent litigation.

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What to do if the Canada Revenue Agency reviews your tax return

10th August 2017

What is a review of your tax return?
The first thing you should know is a review is not an audit.

If the CRA tells you that your tax return is being reviewed, it is simply to ensure that the amounts you have claimed are reported accurately. 

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CRA's Power To Compel Information Protected Under Solicitor-Client Privilege — Canadian Tax Lawyer Analysis

30th July 2017

Legal privilege protects information from disclosure. That is, if your conversation with another person qualifies as privileged, that person cannot be compelled to reveal the contents of that conversation. Canadian courts repeatedly recognize solicitor-client privilege as a fundamental tenet of our legal system.

Yet Canada's Income Tax Act grants the CRA with broad powers to collect—and force individuals to reveal—information for the purpose of enforcing tax laws.

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Personal Investor: CRA cracking down on TFSA ‘winners’

22nd June 2017

The “tax free” part of the tax free savings account could be in question for Canadians with hyper-active TFSAs.

The Canada Revenue Agency (CRA) has revealed it has been reviewing millions of dollars in tax savings from traders who might be considered businesses. TFSAs were introduced nearly a decade ago to allow individual Canadians to invest and not have to pay any tax on the gains. As the total limits on TFSAs grow there are concerns professional investors are using their TFSA’s as a tax dodge.

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