Case Commentary: Court-Ordered Immediate Seizure (‘Jeopardy Order’) of Taxpayer Assets when Canada Revenue Agency Suspects Fraud, Tax Evasion – Canada (National Revenue) v. Ne’eman Foundation Canada, 2024 FC 1932
What is a Jeopardy Order? A jeopardy order is a…
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Beware CRA’s Ability to Share Information with Foreign Tax Authorities Using Tax Information-Exchange Provision In Bilateral Tax Treaties And Tax Information Exchange Agreements: A Canadian Tax Lawyer’s Primer
Introduction: CRA Has the Ability to Exchange Tax-related Information with…
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Can CRA Collect Tax on Your Foreign Assets? Yes, Tax Collection Assistance Provisions Exist Between Canada and other Countries, Canadian Tax Lawyer Explains
Introduction: The Collection-Assistance Provision in Tax Treaties Between Canada And…
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Case Commentary: Csak v the King 2024 TCC – Transfers of property while owing taxes to the CRA (Tax Court Finds Both 1988 and 1989 Reassessments of Maria Csak Statue-Barred)
Introduction – receiving property from a spouse with tax debt…
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CRA’s ex parte Jeopardy Order Application Must Provide Full and Frank Disclosure: Guidance from a Canadian Tax Lawyer
Jeopardy Order allows CRA to seize taxpayer assets Jeopardy orders…
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6075420 Canada Inc. v M.N.R.: A Canadian Tax Lawyer’s Guidance on Reassessment Limitation Periods
Introduction – Exploring the Normal Reassessment Period and “Statute-Barred” Tax…
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Oddi v CRA: Guidance from a Canadian Tax Lawyer Regarding CRA’s Collection Misconduct
Taxpayer sought damages against the CRA for sale of property…
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MNR v Zhao – Guidance from a Canadian Tax Lawyer on the Canada Revenue Agency’s Collection Action When There Are Reasonable Grounds for Delay
The Canada Revenue Agency filed an ex parte application to…
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Transfers Between Spouses Don’t Invoke Vicarious Tax Liability
Tax Guidance: A Transfer Between Spouses Doesn’t Invoke Vicarious Tax…
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Canadian Tax Lawyer’s Analysis of Tax Collections Limitation Period
Introduction – taxpayer’s request for tax credits refund was rejected…
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