The CRA runs a volunteer tax preparer program, which is a Smart Idea. Beginning in 2016, the CRA will require all volunteer preparers to get police checks, which is a Dumb Idea.
Estate freezes and accounting
KPMG reports that If you’re a business owner and you have carried out an estate freeze to fix the value of your shares in the business so that future growth accrues to the benefit of other family members, you may…
Consent steeplechase
Craig Burley reports on the latest from the CRA about authorizations. Apparently Tax Centres are no longer processing faxed authorization forms. Update December 19, 2014. I spoke to an Appeals officer today who said that I couldn’t fax an authorization…
97(2) Abuse
The CRA says that forming a partnership consisting only of Canadian partners to take advantage of the 97(2) rollover and then immediately afterward adding a non-resident partner is abusive. It would attempt to apply the GAAR. (CTF Roundtable Q6).
Restrictive covenant relief
Earlier this year, the CRA said that nominal consideration for a non-compete would be proceeds of disposition so that 56.4(7) would not apply to the covenant. Apparently, the CRA reversed this position at the CTF Roundtable yesterday: $1 (but no…
New folio on amalgamations
The CRA has published a new folio on amalgamations here.
Tax simplification
John Manley, speaking at the Canadian Tax Foundation‘s national conference yesterday, made the case for tax simplification. To which I say “Hah!” I’m just waiting for the “My grandfather was a Greek immigrant who ran a restaurant in North Bay…
HST and damages
Greg Sawatsky has written a helpful summary of the HST rules applying to certain payments of damages.
Objections Can Result in a Bigger Tax Bill
The CRA takes the position that an Appeals officer can issue a reassessment that increases a tax liability if new information supporting the increase comes to light as part of the objection process. Amanda Doucette, “Filing a Notice of Objection…
Loss Carrybacks and Reassessments
Alex Klyguine reminds us that, if the CRA reassesses a year and the taxpayer wishes to dispute the reassessment, the taxpayer must be cautious about applying losses of other years to reduce the taxable income of the reassessed year. If…