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Published: January 11, 2022

Last Updated: October 21, 2022

Case issue

Alleging receipt of unpaid shareholder loans, the CRA increased our client’s taxable income by $567,000. 


We filed a notice of objection, convincing the CRA appeals officer to reduce the amount by $61,500. We then filed a notice of appeal to the Tax Court of Canada. We secured an additional reduction of $373,000 during a pre-trial settlement with the Canada Revenue Agency and the Department of Justice. 


Our client’s taxable income was reduced by a total of $434,500.


"This article provides information of a general nature only. It is only current at the posting date. It is not updated and it may no longer be current. It does not provide legal advice nor can it or should it be relied upon. All tax situations are specific to their facts and will differ from the situations in the articles. If you have specific legal questions you should consult a lawyer."

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