ARTICLE · 16 APRIL 2021

Where Can You Go When The CRA Says No?

Goldman Sloan Nash & Haber LLP

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Two taxpayers, Mr. Born Yesterday and his wife, Ms. Hopelessly Naïve, became your clients two years ago. Previously, they had used the services of a tax advisor, Mr. Artful Dodger.

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Two taxpayers, Mr. Born Yesterday and his wife, Ms. Hopelessly Naïve, became your clients two years ago. Previously, they had used the services of a tax advisor, Mr. Artful Dodger. Dodger had introduced Yesterday and Naïve to certain investments which he assured them would save them a bundle of taxes.

Along came the CRA. Two nice gentlemen from the CRA reviewed the tax returns of Yesterday and Naïve and concluded that they had participated in a fraudulent tax scheme. The CRA reassessed the couple all the way back to 2012 and applied a gross negligence penalty and a pile of interest.

Yesterday and Naïve panicked. They dropped Dodger and came to you. You have negotiated with the CRA. You persuaded the CRA to withdraw the gross negligence penalties in return for an agreement to accept the CRA's reassessment for years after the expiry of the relevant normal reassessment periods.

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