Archive for Month: April

How Disobeying CRA Will Result in ‘Contempt of Court’ Charge in Tax Court, Plus Fines and Other Penalties: Minister of National Revenue v. 1718743 Ontario Inc. (Sanderson Outdoor) et al. (2026 FC 435)

Overview: From Tax Request to Court Penalty: What Went Wrong This case concerns the enforcement powers of the Canada Revenue Agency (CRA) and the consequences of failing to comply with a court order under the Income Tax Act. The Federal Court had to decide how to penalize a company...

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CRA Real Estate Tax Audits Using MLS Data: Builder Risk, GST/HST Exposure & Audit Defence Strategies in Canada

Introduction: Rising CRA Real Estate Tax Audit Risk in Canada CRA real estate tax audits have entered a new phase of sophistication, with the Agency increasingly relying on third-party data sources — most notably MLS listings — to identify potential non-compliance. This shift significantly heightens exposure for homeowners, renovators,...

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Judge with gavel in a courtroom

Blake v. Ahmed (2025 BCCA 384): The Court Says, Bring Real Arguments, Not Organized Pseudo-Legal Commercial Arguments (OPCA) —or Don’t Bring a Case

Introduction: Not every case needs a trial: how judges handle baseless arguments and claims The case of Blake v. Ahmed (2025 BCCA 384) concerns a dispute between a taxpayer and government authorities over the collection of unpaid taxes. The British Columbia Court of Appeal was asked to determine whether...

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Young brunette business woman holding full paper bin of crumpled receipts

2251102 Ontario Inc. v. The King – CRA Net Worth Tax Reassessments Triggered by Taxpayer’s Bad Bookkeeping, Lack of Receipts; CRA’s Reassessment Process Hard to Fight Against

Overview – The Burden to Challenge the Factual Basis of the Tax Reassessment In 2251102 Ontario Inc. v. The King, 2026 TCC 61, the Tax Court of Canada considered whether a taxpayer can successfully challenge a tax reassessment based on a net worth analysis where the CRA has relied...

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