When Financial Statements Quietly Create Tax Litigation Problems One of the more overlooked causes of difficult tax litigation is not aggressive tax planning, offshore structures, or complicated corporate reorganizations. It is the ordinary set of [...]
Economic Entity Audits in Canada: Scope, Risk, and Strategic Pushback An “economic entity audit” is not a defined term in the Income Tax Act or Excise Tax Act, but it is a label commonly used [...]
When Should a CPA Call a Tax Litigator? Most tax disputes are resolved long before a courtroom is ever involved. In many cases, a skilled CPA can manage compliance issues, respond to routine audit queries, [...]
The Role of a Tax Litigator During a Corporate Audit A corporate tax audit is not merely an accounting exercise. It is a structured adversarial process that can evolve—sometimes quickly—from information gathering to reassessment and, [...]
Are Uber Drivers Subject to HST? Boylu v. The King, 2025 TCC 192 (Informal Procedure) by Amit Ummat, Tax Litigator Facts The appellant was an Ontario-based Uber driver during 2015 and 2016. Riders booked [...]
Canadian Federal Budget Proposes Amendments to CRA’s Information Gathering Powers BUDGET FOUND HERE By: Amit Ummat Chrystia Freeland, the Canadian Deputy Prime Minister and the Minister of Finance, tabled the 2024 Canadian Federal Budget on [...]
CRA CAN COMPEL TAXPAYERS TO SUBMIT TO ORAL INTERVIEWS Pursuant to the newly enacted subparagraph 231.1(1)(d)(i) of the Income Tax Act, the CRA can now compel a taxpayer to submit to an oral interview. This [...]
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 [...]
CRA Granted Access to Taxpayer Documents During Audit MNR v. Atlas Tube Canada ULC 2018 FC 1086 Summary In this Federal Court case, the Minister brought an application pursuant to section 231.7 of the Income [...]
