Canadian Federal Budget Proposes Amendments to CRA’s Information Gathering Powers BUDGET FOUND HERE By: Amit Ummat and Alisha Butani Chrystia Freeland, the Canadian Deputy Prime Minister and the Minister of Finance, tabled the 2024 Canadian [...]
Time Extensions for Elections Under Section 217 of ITA(Canada) Are Prohibited By: Amit Ummat and Alisha Butani Section 217 of the Income Tax Act R.S.C., 1985, c. 1 (5th Supp.) (the “Act”) Generally Canadian taxpayers [...]
CRA Voluntary Disclosure Program Reviewed 4053893 Canada Inc. v. Canada (National Revenue) 2021 FC 218 DECISION HERE Tax Case Summary 4053893 Canada Inc. (“405”) applied for a second judicial review of the Minister’s decision to [...]
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 [...]
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 [...]
CRA Appeal Refused by Supreme Court of Canada On October 25, 2018, the Supreme Court of Canada notified the public that it declined to hear the Canadian Government's appeal of a lower court decision limiting [...]
Taxpayer Challenges Constitutionality of Income Tax Laws Canada Without Poverty v. A.G. Canada 2018 ONSC 4147 Justice Morgan of the Ontario Superior Court found that the Income Tax Act's restriction on political activities by charitable [...]
Assessments Beyond Statute-Barred Years Introduction Inwest Investments Ltd. v, Canada (National Revenue) 2015 BCSC 1375 (hereinafter ‘Inwest’) came before the British Columbia Supreme Court by way of summary application. The central issue in Inwest was [...]
