Please see this post for an interesting perspective on some of the 2014 Budget’s cross-border measures by my colleague, Jonathan Garbutt of Garbutt Tax Law. In addition, the Tax Lawyers Alliance, Garbutt Tax Law and EMG Transfer Pricing Experts are…
Berg Overturned
The Federal Court of Appeal, at 2014 FCA 25, has overturned the Tax Court decision in Berg v R, 2012 TCC 406, which I wrote about here.
PAC news
From the CRA “Income Tax Technical Publications” email list: “Income Tax Folio Chapter S4-F3-C1: Price Adjustment Clauses has been updated along with its Chapter History page. The effective date of the update is January 14, 2014.”
Ponzi schemes
Ponzi schemes have some “interesting” tax consequences for their unfortunate victims. It seems that the schemes pose some challenges in the bankruptcy context as well. In Samji (Re), 2013 BCSC 2101, the Court approved a settlement under which some of…
Depression
“‘Natural Person’ Tax Evasion Theory Caused ‘Staggering Losses’ At CRA: Report” For some reason, this story depresses me.
Objections and Taxpayer Relief
The following is from an interesting article on mondaq.com by a couple of lawyers at Gowlings: The CRA recently announced a new pilot project allowing CRA appeals officers to consider applications for interest and penalty relief concurrently with notices of…
Kossow appeal dismissed
Apparently, the Federal Court of Appeal has dismissed the taxpayer’s appeal of Kossow v R, 2012 TCC 325. I say “apparently” because the decision was reportedly posted to the Federal Court of Appeal’s website and then taken down rather quickly.
Collections While a Reassessment is Under Objection
Can the CRA force a taxpayer to provide information about net worth and the location and identity of assets for the purposes of assessing the “credit risk” of a debt owing pursuant to an assessment when that assessment is under…
More tax in the news
Is it me, or is tax attracting more attention in the news lately (like over the last two or three years)? Here’s an article on tax and corporate finance.
CRA information flow
The OBA tax section sponsored a good session today on “Best Practices for Managing the Flow of Information to and from the Canada Revenue Agency”. A couple of interesting tidbits that came out: 1. Some folks at the CRA seem…