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Searching Content indexed under Audit by Rotfleisch & Samulovitch P.C. ordered by Published Date Descending.
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A Taxpayer Need Not Answer Questions During A CRA Tax Audit: Minister Of National Revenue v Cameco Corporation, 2019 FCA 67
MNR v Cameco Corporation (2019 FCA 67) shows that the Canada Revenue Agency's tax-audit powers—while broad—come with limits.
Canada
20 Aug 2019
2
Canada (National Revenue) v Atlas Tube Canada ULC – CRA Ability To Compel Confidential Reports-Canadian Tax Lawyer's Analysis And Comments
In 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.
Canada
18 Jul 2019
3
Case Comment – MNR v Roofmart Ontario Inc. ("Roofmart")
The CRA has general powers to require persons to provide information related to a tax audit however these general powers are limited, such that, the CRA cannot require persons to provide third party documents without judicial authorization.
Canada
4 Jul 2019
4
Canada's Auditor General Slams The Canada Revenue Agency For Unfair Treatment Of Taxpayers
On September 18, 2018, the Auditor General of Canada released its audit report on the Canada Revenue Agency's tax compliance efforts.
Canada
3 Dec 2018
5
Indirect Income Verification
The Canada Revenue Agency isn't shy about pursuing a tax audit. But the CRA invokes its most aggressive tactics when auditing small and medium businesses—groups that the CRA perceives as most likely to retain poor records or lack internal controls.
Canada
12 Nov 2018
6
Net-Worth Tax Assessments And The Onus Of Proof In Tax Cases: Toronto Tax Lawyer Case Review - Truong v The Queen, 2017 TCC 22
On October 18, 2018 the Supreme Court of Canada summarily dismissed an Appeal from the Federal Court of Appeal without reasons, as per its standard practice.
Canada
31 Oct 2018
7
Multiple Taxpayers Successfully Sue The CRA For Damages In Negligence: Ludmer et al c. Attorney General Of Canada
The facts and a detailed analysis by our skilled Canadian tax lawyers follows on this watershed case.
Canada
23 Aug 2018
8
Federal Court Upholds The Canada Revenue Agency's Audit Powers In The Face Of Charter Challenge: Campbell v Attorney General Of Canada, 2018 FC 683
Campbell v Attorney General of Canada (2018 FC 683) provides yet another example of the futility in resisting a Canada Revenue Agency tax audit.
Canada
17 Aug 2018
9
CASE STUDY: Rotfleisch & Samulovitch Successful in Cancelling Tax Trust Exam And Preventing Directors Liability Assessment
Over his career, the entrepreneur started several businesses some of which failed and some of which succeeded.
Canada
17 Jul 2018
10
Challenging CRA Tax Audits – The Reasonable Minimum Standard – Canadian Tax Lawyer Guide
When a Canadian taxpayer is facing a tax audit from the CRA, the conduct and methodology of the tax auditor are subject to a "reasonable minimum standard".
Canada
16 Jul 2018
11
CRA Announces Postal Code Tax Audit Project
While postal code based audits are not new, CRA's formalization of the project is.
Canada
30 Nov 2017
12
Ministry Of National Revenue v Cameco Corporation–Limitations On CRA Tax Audit Powers–Toronto Tax Lawyer Case Comment
Cameco Corporation ("Cameco") refused to grant the Canada Revenue Agency ("CRA") oral interviews with 25 employees and former employees during the course of a transfer pricing tax audit.
Canada
13 Nov 2017
13
Claiming Expenses Without Supporting Tax Documentation – A Canadian Tax Lawyer Analysis
For small businesses and businesses in general, maintaining organized books and records is essential to the business being able to withstand scrutiny on a thorough CRA tax audit.
Canada
13 Oct 2017
14
When Tax-Free Savings Accounts Are No Longer Tax Free: The Canada Revenue Agency's Aggressive Audit Campaign Against TFSAs Carrying On A Business—A Canadian Tax Lawyer's Analysis
Introduced in 2009, the tax-free savings account allows individuals to set money aside tax free. While you cannot claim tax deductions for your TFSA contributions, the TFSA's earnings are tax free even when withdrawn.
Canada
25 Sep 2017
15
GST/HST Tax Audit – Builders Of Residential Real Property And Self-Supply – A Canadian Tax Lawyer Analysis
Building a new home, or renovating an old one, can be a stressful and overwhelming process. CRA can add to the stress by conducting a GST/HST Tax Audit.
Canada
7 Sep 2017
16
CRA's Power To Compel Information Protected Under Solicitor-Client Privilege — Canadian Tax Lawyer Analysis
Legal privilege protects information from disclosure. That is, if your conversation with another person qualifies as privileged, that person cannot be compelled to reveal the contents of that conversation.
Canada
27 Jul 2017
17
CRA Net Worth Audits
CRA is making more use of indirect tax audit techniques, including net worth tax audits.
Canada
12 Jul 2017
18
Background - BP Canada Energy Company v. Canada (National Revenue)
In a ruling delivered on March 30, 2017, the Federal Court of Appeal allowed BP Canada's tax appeal and dismissed the application brought by the Minister pursuant to ss.231.1(1) Income Tax Act...
Canada
3 May 2017
19
CRA Tax Audit Data Analysis
CRA is extending the scope of its tax audit techniques by entering the field of data analysis.
Canada
28 Mar 2017
20
CRA Review By The Auditor General Of Canada Expert Canadian Tax Lawyers Commentary
The CRA could not set consistent expected times with respect to settlements of tax objections.
Canada
15 Feb 2017
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