Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 05 SEPTEMBER 2025

CRA To Acquire Strong New Audit Powers

Borden Ladner Gervais LLP
Borden Ladner Gervais LLP
Contributor
Borden Ladner Gervais LLP

Borden Ladner Gervais LLP

With over 750 lawyers, intellectual property agents and other professionals, BLG services...

View firm profile
Explore more from Borden Ladner Gervais LLP

As part of Budget 2024, the Department of Finance Canada (Finance) introduced proposed legislation to significantly enhance the Canada Revenue Agency's (CRA) audit powers (see previous article here summarizing the initial proposed changes).

CanadaTax
Patrick Reynaud
Patrick Reynaud
Laura Jochimski
Laura Jochimski
Author LinkedIn connections

As part of Budget 2024, the Department of Finance Canada (Finance) introduced proposed legislation to significantly enhance the Canada Revenue Agency's (CRA) audit powers (see previous article here summarizing the initial proposed changes).

On August 15, 2025, Finance announced changes to the proposed legislation (the 2025 Changes). While the 2025 Changes soften some of the hard edges of the Budget 2024 proposals, the application of CRA's new powers remains a concern.

What you need to know:

  • Budget 2024 proposed that when CRA is successful in seeking a compliance order at the Federal Court against a taxpayer, CRA can impose a penalty of 10 per cent of the aggregate tax payable for each year in respect of which the order relates. The 2025 Changes provide that:
    • the penalty can be vacated or reduced at CRA's discretion if "disproportionate or unfair", and

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

How To Appeal The Toronto Vacant Home (VHT) Tax: Here’s What One Landlord Did To Fight VHT Assessment

Since 2022, the City of Toronto has imposed an annual Vacant Home Tax (VHT) on residential units left unoccupied for more than six months of the year. For most owners the tax is an afterthought: file the annual declaration, confirm the unit was lived in, and move on. But when the City’s administrative process breaks down, an owner can find themselves fighting a five-figure tax bill over a unit they insist was never vacant at all.
CanadaTax
Rotfleisch & Samulovitch P.C.
Rotfleisch & Samulovitch P.C.
Article

Cryptocurrency Held Through A Bare Trustee: Tax Treatment And The 2026 Reporting Obligations

If you hold cryptocurrency, NFTs or other blockchain assets in someone else’s wallet, or hold assets in your own wallet for someone else, the arrangement is very likely a bare trust. Until recently, that carried almost no compliance consequence. It now carries three reporting obligations to track: the T3 filing for 2026, the T1135, and the proposed Crypto-Asset Reporting Framework from 2027.
CanadaTax
Rotfleisch & Samulovitch P.C.
Rotfleisch & Samulovitch P.C.
Article

Productivity Mega Deduction: Key Tax Measures Announced At The Canada Investment Summit

Canada has introduced a permanent Productivity Mega Deduction allowing immediate expensing of up to 100% of eligible capital property costs and Canadian development expenses acquired after September 15, 2026. This measure aims to boost business investment and strengthen Canada's tax competitiveness by expanding immediate expensing eligibility from 15% to approximately two-thirds of capital investments, while reducing the country's marginal effective tax rate to 6.4%.
CanadaTax
McCarthy Tétrault
McCarthy Tétrault
Article

From Duties To Import Bans: The Canada–U.S. Tariff War After The Collapse Of Negotiations

The United States has escalated its trade dispute with Canada by imposing import bans on alcoholic beverages, dairy products, and motorcycles under Section 338 of the Tariff Act of 1930, while Canada responds with matched counter-tariffs on $27.6 billion worth of U.S. goods. Following the collapse of bilateral negotiations in August 2026, both nations have entered an unprecedented phase of trade restrictions that extends beyond traditional tariffs to include procurement exclusions and threatens further auto
GlobalInternational Law
Borden Ladner Gervais LLP
Borden Ladner Gervais LLP
Article

New AI Safety Standard Relevant To Canadian School Boards

A major U.S. vendor agreement has established a rigorous new AI safety standard for educational technology, prohibiting the use of student data for AI training and enforcing strict data minimization. While the standard does not directly bind vendors in Canada, Canadian school boards can leverage this precedent to demand equivalent contractual protections and strengthen their own AI governance frameworks.
CanadaTechnology
Borden Ladner Gervais LLP
Borden Ladner Gervais LLP
Article

BLG At The SCC – What’s Coming In The Supreme Court’s Fall 2026 Sitting Schedule

The Supreme Court of Canada held its second annual ceremony marking the opening of the judicial year at its temporary home in the West Memorial Building, with Chief Justice highlighting the Court's increased caseload and architectural features. What significant constitutional and legal challenges will the Court address in its fall 2026 session, including cases on firearm regulations, Crown immunity, and vicarious liability?
CanadaLitigation, Mediation & Arbitration
Borden Ladner Gervais LLP
Borden Ladner Gervais LLP
Article

A New Structure Enters The Ring: CIRO’s Incorporated Approved Person Compensation Proposal

The Canadian Investment Regulatory Organization’s (CIRO) proposed Incorporated Approved Person model could materially change how client-facing advisors structure their businesses and receive compensation with significant impacts to sponsoring firms. The proposed rule amendments, published on July 9, 2026, would introduce a harmonized incorporated compensation option for client-facing Approved Persons across CIRO regulated dealers. Comments are due November 6, 2026.
CanadaFinance and Banking
Borden Ladner Gervais LLP
Borden Ladner Gervais LLP
Article

The Compliance Judges’ Scorecard: OSC RIE Division 2026 Annual Report

Cybersecurity, artificial intelligence, fee practices and the quality of regulatory filings feature prominently in the Ontario Securities Commission’s (OSC) latest account of its registration and examination work. OSC Staff Notice 33-762, released on October 7, 2026, reports on the Registration, Inspections and Examinations Division’s (RIE) activities for the fiscal year ended March 31, 2026 (Staff Notice).
CanadaCorporate/Commercial Law
Borden Ladner Gervais LLP
Borden Ladner Gervais LLP