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ARTICLE · 29 NOVEMBER 2019

A Tale Of Two Taxpayers: The Fiscal Arbitrators Client

In part one of this series, I considered the situation of a hypothetical wealthy client who was involved in the KPMG tax scheme...

CanadaTax

In part one of this series, I considered the situation of a hypothetical wealthy client who was involved in the KPMG tax scheme promoted by a big accounting firm. In the end, the taxpayer signed a settlement with the CRA. Part two relates the story of a typical client of the Fiscal Arbitrators tax scheme (which can be found in Torres v. Canada 2013 T.C.J. No. 332). While the general fact patterns between the groups are similar in broad strokes, the outcomes are not.

The Fiscal Arbitrators Client

The client is a working-class individual who is employed at a factory. He has $125,000 of equity in his home and savings and investments of $23,000. The taxpayer has a grade 12 education and has never taken any tax, business or accounting classes. The taxpayer was sold on the idea of the Fiscal Arbitrators program during a seminar by a flashy salesman and con man who would end up going to prison for his part in the scheme. The taxpayer bought the story hook, line and

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