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1
Auditor General Provides Recommendations For Improving CRA Review Of Objections
Under the federal Income Tax Act, the Canada Revenue Agency must consider a taxpayer's objection and must vacate, confirm or vary the underlying tax assessment.
Canada
1 Dec 2016
2
CRA Ends Political Activities Audit Program For Charities
On January 20, the CRA announced that its controversial political activities audit program for charities has been wound-down.
Canada
24 Jan 2016
3
Tax Court: CRA Employee May Not Testify As Expert
In HLP Solution Inc. v. The Queen (2015 TCC 41 ) the Tax Court held that a CRA employee lacked the necessary impartiality to testify as an expert witness because of her prior involvement in auditing the taxpayer.
Canada
17 Sep 2015
4
Foreign Charities And The Changing Landscape Of CRA Charity Audits
Donors and charities would be prudent to monitor these developments and obtain professional advice where necessary.
Canada
23 Oct 2014
5
International And Transfer Pricing Audits: Toronto Centre Canada Revenue Agency & Professionals Breakfast Seminar
At the Toronto Centre Canada Revenue Agency & Professionals Breakfast Seminar on February 18, 2014, the CRA provided an update on international and transfer pricing audits.
Canada
23 Feb 2014
6
5 Steps To Transition: The Canada Not-For-Profit Corporations Act
This article is a follow up to our October 2011 article regarding the Canada Not-for-Profit Corporations Act, which had just entered into force.
Canada
18 Oct 2013
7
Canada Revenue Agency Provides Update On Rulings And GAAR At Toronto Centre CRA & Professionals Group Breakfast Seminar
On June 6, 2013, at the Toronto Centre CRA & Professionals Breakfast Seminar, the Canada Revenue Agency discussed (a) recent developments at the Income Tax Rulings Directorate and (b) the process through which the General Anti-Avoidance Rule in section 245 of the "Income Tax Act" may be applied in the course of an audit.
Canada
7 Jun 2013
8
CRA Answers TEI’s Questions About Its New "Risk-Based Audit Process"
The Canada Revenue Agency has now published a set of answers to questions and concerns about the audit process presented to it by the Tax Executives Institute late last year.
Canada
7 Feb 2013
9
Canada Revenue Agency Toronto Centre Tax Services Office Describes Current Audit Issues
The CRA clarified that Tax Earned By Audit remains a metric for measuring "tax at risk", but it is not used to measure the performance of an auditor.
Canada
26 Nov 2012
10
No Recourse To Travel Compensation Fund For Loyalty Points Program Provider
The Ontario Divisional Court recently overturned a decision of the Ontario Licensing and Appeals Tribunal that had required the Travel Industry Council of Ontario ("TICO") to compensate a loyalty program provider for the cost of travel services with bankrupt travel services provider.
Canada
15 Mar 2012
11
Highlights Of The 2011 Ontario Economic Outlook And Fiscal Review
This week Ontario’s Finance Minister tabled an update describing the current state of, and future projections for, Ontario’s economy.
Canada
5 Dec 2011
12
5 Steps To Transition: The Canada Not-for‐Profit Corporations Act
The new Canada Not‐for‐Profit Corporations Act ("NFP Act") came into force on October 17, bringing with it a new framework for the governance and incorporation of associations, charities and other federal not‐for‐profit organizations.
Canada
26 Oct 2011
13
5 Steps To Transition: The "Canada Not-For‐Profit Corporations Act "
The new "Canada Not-for-Profit Corporations Act" ("CNCA") is expected to come into force in the summer or fall of 2011, bringing with it a new framework for the governance and incorporation of associations, charities and other federal not-for-profit organizations.
Canada
4 Jul 2011
14
"Braydon" — The Requisite Intent For Fraudulent Conveyances
The British Columbia Court of Appeal’s decision in "Abakhan & Associates Inc. v. Braydon" is of signal import to the insolvency bar and trustees. Leave to appeal to the Supreme Court of Canada has been denied (McLachlin C.J., Abella and Cromwell JJ.).
Canada
17 Jun 2011
15
Rights Of Set‐off In Insolvency
When a company winds up, begins restructuring proceedings or goes bankrupt, a debtor or creditor may be able to cancel out the amount payable to the other party by using the remedy of "set‐off".
Canada
25 May 2011
16
Issues For Litigation
This paper is a summary of some of the litigation issues facing counsel in bankruptcy and insolvency matters and will briefly highlight the following areas:
Canada
17 Mar 2011
17
Show Me The Money! Stalking Horse Auctions In Cross-Border Insolvencies: Value Maximization And An Increase in Transparency
Over the past several years, Canadian courts have embraced the stalking horse bidding process in cross-border insolvency proceedings.
Canada
1 Mar 2011
18
Canada
24 Feb 2011
19
Government Loses its Priority to GST in CCAA Proceedings
In the recent decision of Century Services Inc. v. Canada (Attorney General), 2010 SCC 60, the Supreme Court of Canada has, for the first time, interpreted key provisions of the Companies’ Creditors Arrangement Act ("CCAA").
Canada
6 Jan 2011
20
Court Approval of Cross-Border DIP Financing Guarantees
InterTAN Canada Ltd. ("InterTAN") is a wholly owned subsidiary of U.S. based Circuit City Store, Inc. ("Circuit City"), a consumer electronics retailer.
Canada
20 May 2010
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