Joe Monaco will be giving a presentation at the CRA practitioner’s roundtable on June 5 at the Royal Botanical Gardens.
Refund Interest
Subsection 164(3) of the Income Tax Act (Canada) requires the Minister to pay interest on an amount that is refunded, repaid or applied to another liability.
Charities newsletter
Registered Charities Newsletter No. 29 is now available from the CRA website.
Revocation
The following is an extract from a press release posted on the CRA’s website today:
The Canada Revenue Agency (CRA) has revoked the registered charity status of the Francis Jude Wilson Foundation, a Montreal-area charity. This revocation was effective February 23, 2008, and follows a letter dated August 27, 2007, that was sent to the Foundation.
Non-competes
Yesterday, I spoke about the new rules for non-competes at an HLA-sponsored seminar. Frankly, my speaking notes aren’t as clear as I would like them to be, even allowing for the fact that the new rules are (needlessly) complex. I…
Estate litigation
From Bleak House: Jarndyce and Jarndyce drones on. This scarecrow of a suit has, in course of time, become so complicated that no man alive knows what it means. The parties to it understand it least, but it has been…
The Long Arm of Section 160
The following article on section 160 of the Income Tax Act (Canada) appeared in the latest edition of the Hamilton Law Association Law Journal. It is an expanded version of one of my posts from August.
Section 160 of the Income Tax Act (the “Act”) permits the CRA to assess “at any time” a taxpayer who receives property for inadequate consideration from a non-arm’s length tax debtor.
Garnishments
A garnishment (or “requirement to pay”) under section 224 of the Income Tax Act can be a real headache for the garnishee. The garnishee is put in the middle of another taxpayer’s troubles with the CRA, and the scope of the requirement is sometimes unclear.
Fairness
Making an application for fairness—or “taxpayer relief” as it is now called—is often a frustrating process for a tax professional. One wonders, sometimes, whether the CRA agent responsible even reads the application. The CRA has issued Information Circular IC07-1 about…
GST and Damages
Damages paid for breach of contract, either pursuant to a judgment or further to a settlement, can be subject to GST. Section 182 of the Excise Tax Act provides that any such amount is deemed to include GST, which the…