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The Canada Revenue Agency recently published a news release, in which it identifies over $1 billion in unpaid taxes in the BC and Ontario real estate sectors since 2015.

The Canada Revenue Agency has confirmed that tax audits can be settled before completion, but significant cases require multiple layers of internal review and approval. Understanding CRA's internal settlement processes, including the role of the Audit File Resolution Committee, can help businesses develop effective strategies for resolving disputes efficiently and avoiding costly objections.

At a recent STEP conference roundtable, the CRA stated that, from January 2014 to April 2016, the CRA had received 2,984 calls (812 of which were from potential informants) and 333 written submissions.

The decision in Bolton Steel Tube Co. Ltd. v. The Queen confirms that the CRA is required to reassess a taxpayer in accordance with terms of settlement.

The Canada Revenue Agency (CRA) has recently revised its administrative guidance on the application of third-party penalties under section 163.2 of the Income Tax Act (Canada) (ITA), broadening the circumstances in which the CRA may apply penalties.

The Canada Revenue Agency ("CRA") made headlines in March over its infamous handling of new compliance and reporting requirements for trusts. Bill C-32, which came into effect on December 15, 2022...

The Canada Revenue Agency (the "CRA") generally assesses taxpayers on the basis of their filed returns and supporting books and records.

The death of a parent or friend can be an extremely difficult time and finding out you've been named Executor can lead to many questions – the first being what are the responsibilities of an Executor?

Subparagraph 165(1)(a)(ii) of the Tax Act only requires, in essence, that a CRA notice of assessment be sent.

This paper provides analysis of one of the foundational elements of the Foreign Account Tax Compliance Act (FATCA) and various intergovernmental agreements (IGAs)...

On February 20, 2026, the Federal Court of Appeal ("FCA") released its decision in Canada v. DAC Investment Holdings Inc., 2026 FCA 35 ("DAC"), overturning the Tax Court of Canada's ("TCC")...

The revised EIFEL rules remain open for consultation until January 6, 2023.

BMO carried on business through U.S. branches and was subject to both U.S. federal and New York City income taxes. After IRS audits for 1997–2001...

Our firm's tax groupies often ask us what is happening in the tax world. Given that we are in the heart of the summer, we thought it would be a good time to list the top five tax matters / issues that we are waiting for.

On March 19, 2008, the Federal Court of Appeal rendered its decision in the “MacKay” appeal, reversing the judgment of the Tax Court of Canada which had found that the GAAR did not apply as none of the transactions at issue constituted an avoidance transaction under paragraph 245(3)(b) of the “Income Tax Act”.

Le budget prévoit des bonifications à deux crédits d'impôt remboursables déjà en place ainsi que l'instauration de deux nouveaux credits d'impôt remboursables.

The recent case of Picard v. Estate Ligotte 2019 QCCA 254 provide an illustration of what happens when a person makes a will but leaves important financial matters either unresolved or left