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From 2020 to 2025, the Canada Revenue Agency (CRA) has significantly increased the use of administrative penalties as a core enforcement tool.

Canadian taxpayers, especially entrepreneurs, real estate investors, high-net-worth professionals, and crypto traders, must understand that a CRA tax audit or a Revenu Québec tax audit may evolve into a criminal investigation.

The case, decided on a motion for partial summary judgment, addresses two very important issues in the development of auditors' liability jurisprudence in Canada...

On October 17, 2022, the Québec Court of Appeal in Centre universitaire de santé McGill c. Lemay held that the voluntary disclosure of a solicitor-client privileged forensic accounting report to a police force in the context...

Proposed amendments to National Instrument 55-101 – Insider Reporting Exemptions (NI 55-101) expand relief from insider reporting requirements.

Campbell v Attorney General of Canada (2018 FC 683) provides yet another example of the futility in resisting a Canada Revenue Agency tax audit.

If you are concerned that you might be selected for an audit, how do you prepare for a possible visit?

Canada’s new transfer pricing rules are in effect for tax years beginning after the 2025 federal budget (i.e., 2026 for calendar year taxpayers). It will be many years before the courts weigh in on the impact of the amendments, but the time for multinationals to ready themselves for CRA audit scrutiny is now. Below, we outline the key changes in the amendments and the practical steps that taxpayers can take today.

The Canada Revenue Agency (CRA) operates within an incentive structure that influences audit behaviour in ways that businesses must consider.

By now most advisors are aware that in Budget 2018 the Federal government introduced, among other things, draft legislation to amend the Income Tax Act that is often referred to as the "Passive Investment Proposals".

Over the last several years, the Canadian federal tax authority, the Canada Revenue Agency, has become increasingly aggressive in auditing the affairs of multinational enterprises.

Welcome to 2017! This Newsletter highlights some of the transactions our Business Law Group was involved with in 2016, providing you with an idea of the depth and breadth of experience our Group has.

In R v Posteraro and Dyck, 2014 BCPC 31, a voir dire about the admissibility of evidence in criminal proceedings for tax evasion, the CRA revealed that it had an internal policy to audit any loss carryover claim exceeding $200,000.

As Toronto tax lawyers we deal with CRA audits and auditors on a daily basis. So what is a tax audit? This article will explain what you can expect to happen if you are audited for taxes.

In Part I of our two-part series on the Canada Revenue Agency's (CRA) expanded audit powers, we discussed the CRA's ability to compel individuals for oral interviews.