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Whether the Canada Revenue Agency (CRA) treats an activity as a business or a hobby is one of the most consequential threshold questions a taxpayer can face in a CRA tax audit.

An individual who is a Canadian tax resident is liable to pay Canadian income tax on worldwide income.

If the CRA denied your business losses, you are likely facing increased tax liability and uncertainty about how to dispute the CRA’s position.

This technical bulletin covers the various developments from January to March 2014.

There has been considerable but largely private debate amongst senior insolvency professionals regarding whether it is appropriate for the auditor of a company to act as its monitor in proceedings under the Companies’ Creditors Arrangement Act 1 (CCAA).

I wish I could tell you how many countries we're in. I don't think I actually know but we are just over 200,000 people as a global organization.

The Canada Revenue Agency’s access to information about cryptocurrency and other crypto-assets is entering a new phase. Canadian taxpayers have always been responsible for identifying, valuing, classifying, and reporting taxable crypto activity, even where an exchange issued no Canadian tax slip, the transaction occurred through a foreign platform, or the assets were never converted into Canadian dollars. 

When the Canada Revenue Agency (CRA) concludes that a GST/HST registrant’s books and records do not provide a complete or reliable picture of its taxable sales, it may reconstruct those sales using an alternative or indirect audit method.

Les contribuables peuvent facilement commettre des erreurs en naviguant dans un différent en matière de prix de transfert s'ils n'ont pas examiné...

A CRA tax audit can be stressful under any circumstances. The situation becomes even more challenging when a taxpayer has suffered a serious injury, faces a substantial tax reassessment based on a CRA net worth audit, and discovers that important procedural opportunities were missed during the early stages of a tax dispute.

The Canada Revenue Agency’s (“CRA”) authority to conduct a cryptocurrency tax audit begins with subsection 231.1(1) of the Income Tax Act. It gives authorized CRA officials broad powers to inspect or examine relevant documents, records, property, processes, and other matters, and to require reasonable assistance and proper oral or written answers.

ACCOUNTING STANDARDS FOR PRIVATE ENTERPRISES (ASPE) - Active projects – watch for further activity on these matters.

Navigating a transfer pricing audit in Canada requires understanding CRA's extensive verification powers, documentation requirements, and the critical importance of protecting attorney-client privilege. This guide examines the audit lifecycle from initial contact through conclusion, including functional interviews, information requests, and the consequences of non-compliance with CRA demands.

Découvrez les stratégies juridiques pour contester une nouvelle cotisation relative aux prix de transfert au Canada, incluant les recours devant l'ARC, la Cour canadienne de l'impôt et les procédures amiables internationales. Ce guide examine les facteurs décisionnels critiques, les considérations liées aux litiges fiscaux et le rôle des témoins experts dans la résolution de différends complexes en matière de prix de transfert.