De Facto Control

In the Canadian income tax case of 9044-2807 Québec Inc. v The Queen, 2004 FCA…

Published: March 20, 2020

Last Updated: April 6, 2020

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Dividend Types under the Canadian Income Tax Act

Introduction – Dividend Types and Ontario Dividend Tax Rates Under the Canadian Income Tax Act…

Published: March 20, 2020

Last Updated: October 21, 2022

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Requirement for CRA to Assess Tax Shelters with Due Dispatch Confirmed by Federal Court

In McNally v. Canada (National Revenue) (2015 FC 767), a case where CRA did not…

Published: March 20, 2020

Last Updated: May 25, 2020

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Ongoing Panama Papers Leak CRA Tax Audits

On January 16 and 17, 2017 CRA participated in a meeting of the Joint International…

Published: March 20, 2020

Last Updated: February 21, 2022

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Solicitor-client privilege for commonly interested parties

Solicitor-Client Privilege Bars the Canada Revenue Agency From Compelling Legal-Advice Documents When a Taxpayer Discloses…

Published: March 20, 2020

Last Updated: April 13, 2020

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Deliberately falsification of Canadian income tax return

If you deliberately falsify your Canadian income tax return, or are grossly negligent in preparing…

Published: March 20, 2020

Last Updated: February 21, 2022

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How to Fight CRA

Most tax returns, corporate or personal, are usually assessed as filed by the taxpayer. In…

Published: March 20, 2020

Last Updated: October 21, 2022

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A Canadian tax lawyer’s perspective on the functional currency election

Currency Reporting Requirements Section 261 of Income Tax Act generally requires amounts reported on Canadian…

Published: March 20, 2020

Last Updated: October 25, 2021

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Sentence and Fine for Tax Fraud

In the case of R. v Wang 2015 BCPC 302 the British Columbia Provincial Court…

Published: March 20, 2020

Last Updated: February 21, 2022

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