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A Federal Court case demonstrates the severe consequences of ignoring Canada Revenue Agency Requests for Information during tax audits. When a landscaping corporation and its principal failed to comply with a court-ordered production of financial documents, they faced substantial fines and a 30-day jail threat, highlighting the critical importance of proper RFI compliance with guidance from experienced tax counsel.

The administrative position of Canada Revenue Agency (CRA) with respect to U.S. limited liability companies (LLCs) has created considerable consternation. CRA consistently repeated its position that LLCs that are treated as fiscally transparent for U.S. tax purposes will not be entitled to the benefits of the Canada-U.S. Tax Convention (the Convention) on the basis that they do not qualify as residents of the U.S. for purposes of the Convention even where all the members are U.S. residents.

Taxpayers are often aware of the common triggers for a Canada Revenue Agency (CRA) audit, such as claiming large expenses, failing to report a tax slip, or simply working in an industry known to underreport their income.

Cybersecurity is one of the greatest threats facing modern businesses.

This information that follows is taken from sources including The Car Connection, Autoweek, Green Car Reports, and other industry sources.

Authorities must relinquish their broad compulsory auditing powers when engaging in an adversarial determination of penal liability or, as stated by the Supreme Court in R. v. Jarvis, [2002] 3 SCR 757 when they "cross the Rubicon".

Institutional Investor Services ("ISS") and Glass Lewis have released their updates to proxy voting guidelines for 2020.

Perhaps the most significant new and evolving development in outsourcing is competitive procurement. More and more customers are approaching the process of choosing an outsourcing service provider through a competitive bidding process with the use of more effective RFPs and a more disciplined process governing responses.

In its recent decision in Ivaco Inc., Re [2006] O.J. No. 4152, the Ontario Court of Appeal dealt with the challenging interplay between pension law and insolvency law. The decision deals with a restructuring in which one of the dominant issues is the treatment of a debtor’s unfunded pension liabilities.

In 2013, our principal stock exchanges and securities regulators updated requirements for listings and raising capital and proposed further changes in these areas.

The requirement under section 7(4) of the Ontario Statutory Accident Benefits Schedule for insurers to fund accounting reports on behalf of insured persons is a reasonable one.

Traditionally, a tax audit has been seen as an administrative process, where a CRA auditor examines the books and records of a taxpayer and proposes adjustments to the characterization...

The ability to borrow and lend securities without significant tax consequences is essential to various capital markets activities including repo financings and hedging the obligations created by certain derivative products. U.S.-based securities lenders have traditionally faced difficulties in lending to Canadian-based securities borrowers because of potential withholding tax on payments made as compensation for dividend or interest payments on the borrowed securities.

Aircraft lessors and financiers may be held liable for Canadian air navigation and airport service charges incurred by airlines operating the aircraft as a result of a recent decision by the Supreme Court of Canada.

Tax auditors often request audit waivers when approaching limitation periods, but these seemingly simple agreements carry significant risks for taxpayers.

Earlier this year, the Canadian Accounting Standards Board confirmed January 1, 2011 as the date that International Financial Reporting Standards (IFRS) will replace Canadian generally accepted accounting principles (Canadian GAAP) for all Canadian publicly traded companies as well as for non-listed financial institutions, securities dealers and many cooperative enterprises that qualify as “publicly accountable enterprises.”

The securities regulatory authorities in all Canadian provinces and territories except Ontario and British Columbia have announced their intention to issue harmonized interim local orders that provide exemptions from certain financial statement-related and audit requirements of Form 45-106F2 – Offering memorandum for non-qualifying issuers.