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  • Article

    Canadian Income Tax – Net Worth Audit And Tax Assessments – Toronto Tax Lawyer Analysis

    One of the most common, powerful and from a taxpayer point of view troublesome methods employed by the CRA to assess the income of a taxpayer is the net worth audit.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    Indirect Income Verification

    The Canada Revenue Agency isn't shy about pursuing a tax audit. But the CRA invokes its most aggressive tactics when auditing small and medium businesses—groups that the CRA perceives as most likely to retain poor records or lack internal controls.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
Article

Ministry Of National Revenue v Cameco Corporation–Limitations On CRA Tax Audit Powers–Toronto Tax Lawyer Case Comment

Cameco Corporation ("Cameco") refused to grant the Canada Revenue Agency ("CRA") oral interviews with 25 employees and former employees during the course of a transfer pricing tax audit.
CanadaTax
Rotfleisch & Samulovitch P.C.
Rotfleisch & Samulovitch P.C.
  • Article

    Tax Avoidance And Evasion: Government Of Canada Report Recommends Action

    The government of Canada's recent report responding to the Finance Committee Report "The Canada Revenue Agency, Tax Avoidance and Tax Evasion: Recommended Actions" in turn recommended a number of actions...
    CanadaTax
    Gowling WLG
    Gowling WLG
  • Article

    Enhanced Documentation Requirements For Research And Development Tax Credits In

    CanadaAccounting and Audit
    PwC Management Services LP
    PwC Management Services LP
  • Article

    Court Of Appeal Confirms Accounting Firms May Take On Multiple Mandates For The Same Company

    The Newfoundland and Labrador Court of Appeal recently confirmed that accounting/auditing firms may take on several mandates...
    CanadaInsolvency/Bankruptcy/Re-Structuring
    Stewart McKelvey
    Stewart McKelvey
  • Article

    Winter And FATCA/CRS Audits Are Coming For Financial Institutions

    The Canada Revenue Agency (CRA) will shortly begin on-site audits of financial institutions (FIs) for purposes of Part XVIII (FATCA) and Part XIX (CRS) of the Income Tax Act.
    CanadaAccounting and Audit
    Borden Ladner Gervais LLP
    Borden Ladner Gervais LLP
  • Article

    It's Debatable: Unresolved Corporate Governance Issues Impacting 2025

    Views are divided on the right approach to address many important corporate governance concerns. Among these is whether virtual shareholder meetings for public companies are beneficial for or detrimental to shareholder democracy.
    CanadaCorporate/Commercial Law
    Osler, Hoskin & Harcourt LLP
    Osler, Hoskin & Harcourt LLP
  • Article

    Defamation On The Inter-Office Electronic Bulletin Board: Is The Employer Responsible?

    CanadaIntellectual Property
    Gowling WLG
    Gowling WLG
  • Article

    Be Careful What You Ask For: Limits On Oral Interviews Confirmed In Cameco

    MNR v Cameco Corporation, 2019 FCA 67 ("Cameco") was an unsuccessful appeal by the Crown of a failed compliance order application in the Federal Court ("FC").
    CanadaTax
    Gowling WLG
    Gowling WLG
  • Article

    Challenging CRA Tax Audits – The Reasonable Minimum Standard – Canadian Tax Lawyer Guide

    When a Canadian taxpayer is facing a tax audit from the CRA, the conduct and methodology of the tax auditor are subject to a "reasonable minimum standard".
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    CRA's Power To Audit And Assess: New Developments, Old Problems

    The Canada Revenue Agency (CRA) is afforded considerable latitude in administering and enforcing the Income Tax Act (Act). This latitude is reflected in its power to determine the scope of tax audits...
    CanadaTax
    Osler, Hoskin & Harcourt LLP
    Osler, Hoskin & Harcourt LLP
  • Article

    Federal Court Of Appeal Confirms CRA Can Collect Arrears Interest Despite Absence Of A Tax Debt

    The Federal Court of Appeal (FCA) recently dismissed the Bank of Nova Scotia's (BNS) appeal and upheld the Canada Revenue Agency's (CRA) practice of charging arrears interest on a non-existent tax debt
    CanadaTax
    Davies Ward Phillips & Vineberg LLP
    Davies Ward Phillips & Vineberg LLP
  • Article

    How To Deal With A Cryptocurrency Tax Audit: Guidance From A Canadian Tax Lawyer

    Many tax agencies and regulatory bodies around the world have increasingly focused on cryptocurrency traders for the past several years, in particular the IRS and the CRA.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    The Canada Revenue Agency's Expanded Audit Powers: What Taxpayers Need To Know

    The Canada Revenue Agency (CRA) recently made headlines when it asked Shopify for six years' worth of records for more than 120,000 of its Canadian customers.
    CanadaTax
    Dentons Canada LLP
    Dentons Canada LLP
  • Article

    What To Do When The CRA Comes Knocking…

    You’ve just received a letter from the Canada Revenue Agency. They intend to conduct a tax audit of your company for the past three years.
    CanadaAccounting and Audit
    PwC Management Services LP
    PwC Management Services LP
  • Article

    CRA's Power To Compel Information Protected Under Solicitor-Client Privilege — Canadian Tax Lawyer Analysis

    Legal privilege protects information from disclosure. That is, if your conversation with another person qualifies as privileged, that person cannot be compelled to reveal the contents of that conversation.
    CanadaTax
    Rotfleisch & Samulovitch P.C.
    Rotfleisch & Samulovitch P.C.
  • Article

    A New Level Of Trust & Transparency

    This paper focuses on the changes from the Section 5970 standard to the new CSAE 3416 standard, including comments on the impact of those updates on service organizations and service auditors
    CanadaAccounting and Audit
    PwC Management Services LP
    PwC Management Services LP
  • Article

    Revenue Canada Comments On Tax Shelters

    CanadaAccounting and Audit
    PwC Management Services LP
    PwC Management Services LP
  • Article

    Privacy Commissioner Confirms Original Outsourcing Guidance

    On August 4, 2020, the Office of the Privacy Commissioner of Canada (OPC) released a set of findings1 concerning a decision by TD Canada Trust (TD)
    CanadaEmployment and HR
    Cassels
    Cassels
  • Showing 401–420 of 617 results

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