Liu et al v The King and the Limits on Alternative Arguments in Tax Court Pleadings The Tax Court strikes the CRA’s attempt to plead a foreign accrual property income theory that was never part of the original tax reassessment, reaffirming firm limits on what subsection 152(9) permits. Liu...
Contents Overview: When a CRA Reassessment You Never Received Can Still Affect Your Objection Rights What Happened in Ducharme? The CRA’s $15.8 Million Penalty Reassessments and Motion to Quash Why Does the Mailing Date of a CRA Tax Assessment or Reassessment Matter? What Happens If the CRA Cannot Prove...
Overview A Tel Aviv District Court sentence handed down against a veteran Israeli actor and entrepreneur is a useful lens for Canadian taxpayers who want to understand how much more exposure they face if the Canada Revenue Agency (CRA) refers their file for criminal tax evasion prosecution. The Israeli...
Contents: CRA Requirement to Pay: When Can a Third Party Become Personally Liable for Another Taxpayer’s Tax Debt? A Canadian Tax Lawyer’s Analysis of Dejifasanya v. The King Overview: When a CRA Requirement to Pay Can Turn Someone Else’s Tax Debt Into Your Own Liability How Does a CRA...
Overview: When a Tax Fraud Guilty Plea Comes Back to Haunt a Taxpayer Pleading guilty to a tax fraud charge is rarely the end of a taxpayer’s troubles. In Bernier v The King, a taxpayer who pleaded guilty to Income Tax Act and Excise Tax Act offences in 2022...
Can You Deduct Legal Fees Paid for Another Taxpayer’s CRA Dispute? Kruivitsky v. The King Overview: What if I paid Legal Fees or Expenses Regarding Tax Assessment of Another Taxpayer? Background: What Happened Between Ms. Kruivitsky and Mr. Dombroski? Key Issues and Findings: When Are Legal Fees for a...