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ARTICLE · 02 JANUARY 2025

Vaping Audits & Assessments Are Here

Millar Kreklewetz
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When a Canada Revenue Agency (the "CRA") audit concludes and a Proposed Assessment issued, it is presented in a "Statement of Proposed Audit Adjustment". This document outlines the CRA's Assessment.

CanadaInternational Law
Robert Kreklewetz
Robert Kreklewetz

When a Canada Revenue Agency (the "CRA") audit concludes and a Proposed Assessment issued, it is presented in a "Statement of Proposed Audit Adjustment". This document outlines the CRA's Assessment of the additional taxes owed. At this stage, significant work needs to take place to try and understand the basis for the Proposed Assessment and attempt to rebut the CRA's Assessment position.

Because CRA is the "elephant in the room" (and typically does what it wants to do), where an Assessment is finalized and raised, it is a very signification matter, for the following reasons.

Debt Due and Owing

A finalized CRA Assessment is usually deemed a debt owing to His Majesty, which means that CRA Collections can immediately seek payment: in the Vaping Duty context, see for example Excise Act, 2001 ("EA 2001") 188(1) and 284(1.1).

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