Gross Negligence Penalties CRA Must Prove Penalty Applies What many people under audit find is that, in addition to proposing adjustments to income tax payable, the CRA will also apply penalties. There are various penalties [...]
GST/HST Hot Topics Recent Issues in the Input Tax Credit Regime Generally speaking, GST/HST is not considered a significant cost because of the input tax credit (ITC) mechanism. As a GST/HST registrant, you recover the GST/HST [...]
Trading in Shares: Income or Capital? Are you earning income or capital gains by your trading activity? A prominent issue encountered by Canadian taxpayers is whether the gains from the sale of shares are income [...]
What is Involved in a Tax Appeal? Steps in a Tax Court Appeal At Ummat Tax Law, we receive many calls from taxpayers who are simply unaware of what an appeal to Tax Court entails. [...]
Avoiding a CRA Audit We have many clients who are self-employed. We also represent professionals and businesses who are required to keep their own books and a variety of others operating cash-based businesses. These groups [...]
Shareholder Benefits Generally When shareholders receive payments from a corporation in the form of dividends or wages these amounts are included in income. As a shareholder, you need to be aware of other income inclusions [...]
Federal Court Reviews Taxpayer's Application Involving Voluntary Disclosure Relief: 4053893 Canada Inc. v. MNR (2019 FC 51) Case Here Summary In 4053893 Canada Inc. v. MNR,[1] the taxpayer's application for judicial review of the [...]
Recent Costs Awards in the Tax Court of Canada As a general principle of litigation, an unsuccessful party at the Tax Court usually pays a portion of the legal costs of the successful party. In [...]
Know Your Rights We regularly receive calls where the taxpayer has perceived unfair treatment by the Canada Revenue Agency (“CRA”). “Can they actually do this?” is, unfortunately, a popular refrain. Individual and corporate taxpayers should [...]
Tax Court Practice Note on Expert Evidence One of the noblest aspects of practicing tax litigation is the privilege of appearing before the venerable Tax Court. The judges are brilliant, the registrar's office and the [...]