ARTICLE · 28 JUNE 2012

Canada Revenue Agency ("CRA") Trust Audits - An Update

Moodys Private Client Law LLP

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Our firm's June 21, 2010 blog (yes, that's over two years ago), discussed the CRA's domestic trust audit project. Our February 9, 2011 blog discussed the CRA's high net worth audit initiative (or what the CRA calls the "Related Party Initiative" or "RPI" for short).

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Our firm's June 21, 2010 blog (yes, that's over two years ago), discussed the CRA's domestic trust audit project. Our February 9, 2011 blog discussed the CRA's high net worth audit initiative (or what the CRA calls the "Related Party Initiative" or "RPI" for short). These are two very high profile audit initiatives undertaken by the CRA. What is the status of these projects? Good question.

It's difficult to answer the above question with a lot of certainty. The CRA has previously announced that the RPI is targeted at private persons who have more than 30 entities in their corporate group (including corporations, trusts or partnerships) and appear to have a net worth of more than $50 million. A lot of questions arise as to how the CRA is identifying such people but the CRA has been tight-lipped. At the CRA Roundtable at the Society of Trust and Estate Practitioners recent National Conference held on June 12, 2012 in Toronto, ON, the CRA stated they have so far

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