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CRA's tax auditors and tax collectors serve very different functions. Tax auditors from CRA gather information to determine whether your tax returns fully reflect your obligations under the Canadian Income Tax Act.

When a CRA auditor thinks the CRA can take a bigger share of your capital, other CRA agents and the CRA's lawyers will fight to extract it.

Le paysage fiscal québécois peut se résumer comme suit : les vérifications fiscales effectuées sur une base annuelle sont très nombreuses et les processus de contestation peuvent décourager plusieurs contribuables ...

The perception that Internal Revenue Service enforcement is stronger than Canada Revenue Agency enforcement is common among taxpayers and advisors, particularly in cross-border contexts.

In preparation for the upcoming proxy season, we have once again rounded up the key developments in corporate governance and disclosure requirements impacting Canadian public issuers.

On November 29, 2016, the Auditor General of Canada released the 2016 Fall Reports, including "Income Tax Objections"...

The Canada Revenue Agency (“CRA”) is increasingly using artificial intelligence, machine learning, advanced data analytics, and third-party information reporting to identify taxpayers for CRA tax audits and other tax compliance initiatives.

CRA has recognized the power of the methodology to cause harm to the taxpayer resulting from inaccurate and excessive reassessments.

In a recent decision, the Court of Québec permanently stayed the prosecution of tax fraud charges made against a corporation and two related individuals after finding "serious

The CRA's first formal position reshapes liquidity, governance rhythm, and the company's control of the dispute.

In the 2021 Federal Budget, the government proposed the allocation of more than $304 million over the next five years to support audit disclosures through the funding of the Canada Revenue Agency's (CRA)

Selling a business is a significant milestone representing the culmination of years of hard work, dedication, and growth. It requires careful planning and preparation to ensure a smooth transition

As an experienced Canadian tax lawyer specializing in tax audits and investigations, I often advise clients on the critical distinctions between tax audits and criminal investigations under Canadian tax legislation, whether conducted by the Canada Revenue Agency (CRA) or Revenu Québec.

This briefing provides an update on the proposed legislation being considered by the European Commission and debated in the European Parliament and the Council of Ministers.

The facts and a detailed analysis by our skilled Canadian tax lawyers follows on this watershed case.

Business tax audits are a keyway by which the CRA ensures that a business has fulfilled its tax obligations with respect to income tax, payroll deductions, benefits, remittances, and GST/HST, pursuant to the Income Tax Act and the Excise Tax Act.