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Leadership responses at the audit stage now directly shape the trajectory of tax disputes and how boards evaluate the CFO's judgement.

Over the past few years, federal employers with 10 or more employees have been engaged in the important but time-consuming process of developing their initial pay equity plan as required by the new Pay Equity Act (the "Act").

The Canada Revenue Agency has now published a set of answers to questions and concerns about the audit process presented to it by the Tax Executives Institute late last year.

MNR v Cameco Corporation (2019 FCA 67) shows that the Canada Revenue Agency's tax-audit powers—while broad—come with limits.

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).

A key part of the Canadian government's response to the COVID-19 pandemic has been the Canada Emergency Wage Subsidy (CEWS).

Suivant une vérification fiscale effectuée par RQ ou par ARC du Canada, les autorités fiscales peuvent émettre des nouvelles cotisations à l'encontre du contribuable qui a fait l'objet de cette vérification.

The Canada Revenue Agency may examine your TFSA transactions and argue that you were engaged in the business of trading securities within your TFSA.

Canada has become an attractive source of investment opportunities for foreign private equity investors, particularly US investors. In addition to two large transactions led by KKR (the acquisition of Shoppers Drug Mart and the telephone directories business of BCE), there have been a significant number of private equity transactions in the $15-50 million dollar range in recent years. The Canadian private equity market is attractive for a variety of reasons including:

The entitlement of Canadian taxpayers to hold the Canada Revenue Agency ("CRA") liable for egregious tax audit and tax enforcement action remains a new and blossoming concept in Canadian law.

In a ruling delivered on March 30, 2017, the Federal Court of Appeal allowed BP Canada's tax appeal and dismissed the application brought by the Minister pursuant to ss.231.1(1) Income Tax Act...

In this case, the taxpayers, Steve Paquet and his company, 4527976 Canada Inc. ("Héritage"), appealed against income tax assessments for 2010-2013 for Paquet and 2010-2014 for Héritage.

In 2009, the federal government introduced the tax-free savings account ("TFSA") program as a means of promoting investment in the Canadian economy and assisting Canadians in saving for the future.

The Income Tax Act grants the CRA the power to investigate criminal tax evasion as well as non-criminal tax issues of Canadian taxpayers.