ArticleSettlement Finally Reached In Coopers & Lybrand LitigationOn July 15, 2015, the Ontario court granted an Order approving settlement of the Castor Holdings litigation. CanadaInsolvency/Bankruptcy/Re-StructuringMcLennan Ross LLP
Article5 Things To Do When You Get A Letter From The BSAWho is the BSA? The Business Software Alliance ("BSA") is the leading advocate for the global software industry and promotes legal software use. The BSA investigates reports of alleged...CanadaIntellectual PropertyMinden Gross LLP
ArticleAll-important IP AuditsIt is now well established that the most valuable assets of a 21st century business consist of its intellectual property.CanadaIntellectual PropertyGoldman Sloan Nash & Haber LLP
ArticleInternational And Transfer Pricing Audits: Toronto Centre Canada Revenue Agency & Professionals Breakfast SeminarAt the Toronto Centre Canada Revenue Agency & Professionals Breakfast Seminar on February 18, 2014, the CRA provided an update on international and transfer pricing audits.CanadaTaxDentons Canada LLP
ArticleThe Billionaire's Audit: Québec Taxpayer Awarded Damages For Negligent RPI AuditIn 2005, the Canadian Revenue Agency (CRA) launched the Related Party Initiative (RPI), more commonly referred to as the High-Net-Worth Project or the Billionaire's Audit.CanadaAccounting and AuditBorden Ladner Gervais LLP
ArticleTax Treaty Implications For U.S. Residents Receiving Canadian Social Security BeCanadaTaxPwC Management Services LP
ArticleRevisiting Home Audits And Confidential Client InformationIn 2021, I predicted that CIRO would begin auditing Canadian dealers to ensure proper supervision and controls over remote work. CanadaPrivacyBabin Bessner Spry LLP
ArticleCanada (National Revenue) v Atlas Tube Canada ULC – CRA Ability To Compel Confidential Reports-Canadian Tax Lawyer's Analysis And CommentsIn Canada (National Revenue) v Atlas Tube Canada ULC, the Federal Court held that Canada Revenue Agency could compel a private corporation to disclose its draft tax due diligence report during the course of an ongoing audit.CanadaTaxRotfleisch & Samulovitch P.C.
ArticleCRA Audits Casino Records Of Canadian GamblersIn a new audit approach CRA has been reviewing the records of Canadian casinos and sending proposed tax assessments amounting to multi millions of dollars to Canadian gamblers on the basis of unreported income. CanadaTaxRotfleisch & Samulovitch P.C.
ArticleDenial Of GST/HST Input Tax Credits As Per The Agent-Principal CharacterizationCanada Revenue Agency audits have targeted Canadian sales to foreign entities. CanadaTaxSpenceDrake Tax Law
ArticleMake A List And Check It Twice: Record All Information Provided To A CRA AuditorWhen we performed the same audit on the same documents, the assessment was almost zero. CanadaTaxLexSage
ArticleUnderground Economy Tax Evasion Remains CRA PriorityAs Canadian tax lawyers we provide income tax advice to taxpayers who have engaged in unreported cash transactions and have decided to correct their back tax filings. CanadaTaxRotfleisch & Samulovitch P.C.
ArticleCRA NewsIn August 2024, the Canada Revenue Agency (CRA) released a number of updates on its News and events for charities page, including the following, discussed below.CanadaCorporate/Commercial LawCarters Professional Corporation
ArticleCBSA Audit PrioritiesThe Canada Border Services Agency ("CBSA") resets its "audit priority areas" twice per year. Essentially, the CBSA designates certain tariff classification codes...CanadaInternational LawMillar Kreklewetz
ArticleSupreme Court Of Canada Restores Dismissal Of $50 Million Auditor's Negligence Claim Due To Expired Limitation PeriodIn a unanimous decision released this morning in Grant Thornton LLP v. New Brunswick, the Supreme Court of Canada restored a judgment of the New Brunswick Queen's Bench that dismissed as statute-barred a $50 million ...CanadaLitigation, Mediation & ArbitrationAffleck Greene McMurtry LLP
ArticleNavigating Builder AuditsBuilder audits conducted by the Canada Revenue Agency (CRA) are a significant concern for taxpayers involved in real estate transactions, particularly those engaged in construction or substantial renovation projects.CanadaReal Estate and ConstructionRosen & Associates
ArticleCRA Net Worth Audit - Challenging Necessity And MethodologyAccording to the Tax Court of Canada in Ramey v. The Queen, 93 DTC 791 (Ramey), at paragraph 6, the "net worth method of estimating income is an unsatisfactory and imprecise way...CanadaTaxSpenceDrake Tax Law
ArticleNew Considerations When Seeking To Multiply Access To The Lifetime Capital Gains ExemptionProactive planning to multiply access to the lifetime capital gains exemption ("LCGE") for shares of a qualified small business corporation ("QSBC") or qualified family farm property...CanadaTaxMiller Thomson
ArticleSeven Areas The Canada Revenue Agency Is ScrutinizingThe 2021 Federal Budget devoted an additional $304.1 million to the CRA to help it combat tax evasion and aggressive tax avoidance. CanadaTaxFasken