Archive for Category: CRA Tax Audit

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T1135s, Beneficial Ownership of Property, and Chan v The Queen: A Canadian Tax Lawyer’s Case Comment

Introduction – T1135s and Beneficial Ownership The Canadian Income Tax Act requires that Canadian tax residents who own “specified foreign property” with a cost of $100,000 or more in Canadian dollars file an annual Foreign Income Verification Statement, or “T1135”, with that year’s tax return. Specified foreign property as...

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Couple sitting at desk with coffee, calculator and paperwork discussing taxes

Federal Court of Appeal Overturns Tax Court’s Decision and Vacates Gross-Negligence Penalties because the Canada Revenue Agency’s Evidence was Exclusively About the Taxpayer’s Spouse: Khanna v The Queen, 2022 FCA 84 – A Canadian Tax Lawyer’s Analysis

Penalties Canada’s tax statutes contain various penalties that seek to curb non-compliance. A gross-negligence penalty aims to punish a taxpayer whose conduct “involves a high degree of negligence tantamount to intentional acting, an indifference as to whether the law is complied with or not”: Venne v R., 84 DTC...

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CRA's Agreement with Coinsquare in Disclosing Crypto User Information

CRA’s Agreement with Coinsquare in Disclosing Crypto User Information

Introduction – CRA’s Court Order against Coinsquare On September 18, 2020, the CRA filed a Federal Court application against Coinsquare in order to compell the Toronto-based cryptocurrency platform to disclose tax information related to its customers. We covered this issue in depth here (https://taxpage.com/articles-and-tips/cra-wants-coinsquare-to-disclose-confidential-client-info/) Following a Federal Court ruling...

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Upward Adjustments for Tax Notices of Objection

Upward Adjustments for Tax Notices of Objection

What is a Tax Notice of Objection? A tax Notice of Objection is a formal dispute filed with the Canada Revenue Agency wherein the taxpayer appeals tax amounts assessed against the taxpayer by the Canada Revenue Agency. For example, a taxpayer may argue an auditor improperly imputed taxable income...

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Tax Guide for Crypto & Bitcoin Businesses: Computing Inventory Costs

Introduction: Cryptocurrency-Trading Businesses in Canada Canadian cryptocurrency-trading businesses face unique challenges. The mostly unregulated market brings higher risk of fraud and cyber-crime. The volatile markets may bleed profits. And some cryptocurrency traders don’t even realize that they’re carrying on a business, misreporting their profits as capital gains. This article...

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