The Dilemma: Corporate Status vs. Tax Obligations The dissolution of a corporation creates confusion regarding its tax filing obligations. The question often boils down to: Does a dissolved corporation need to be legally revived to file outstanding tax returns with the Canada Revenue Agency (CRA)? For a corporation created...
The Underused Housing Tax Act (UHTA) imposes a particularly severe penalty regime for property owners who fail to file their required returns on time. The most punitive element—often overlooked—is the December 31 late-filing rule, which can expose even tax-exempt owners to ongoing penalties as if they owed tax. For...
Missed Deadlines for Objections and the Jurisdictional Bar of the One-Year Rule The Income Tax Act sets strict deadlines for taxpayers to object to tax assessments or reassessments or request extensions. Under paragraph 165(1)(b), taxpayers—including individuals and corporations—must serve a notice of objection within 90 days of the assessment’s...
Overview – A Landmark Warning to CRA on Tax Litigation Conduct In Choptiany et al. v. The King (2022 TCC 112), the Tax Court of Canada delivered one of the most striking procedural rebukes against the Canada Revenue Agency (CRA) and the Department of Justice. The case involved three...
RESP Withdrawals: What Every Contributor and Beneficiary Should Know About Taxes A Registered Education Savings Plan (RESP) is a government-supported savings vehicle that helps Canadians set aside funds for the post-secondary education of their children or other eligible beneficiaries. Despite its popularity, many Canadians—including both contributors and beneficiaries—remain unclear...
Have You Made a Mistake on Your Tax Return? Here Is How to Correct It. It is not uncommon for individuals to file their taxes and then realize they have made a mistake. Perhaps a slip arrived late and was not included in the return, some income was accidentally...
Introduction – GAAR, Surplus Stripping and the Use of PUC Averaging The general anti-avoidance rule (GAAR) in section 245 of the Income Tax Act is designed to prevent taxpayers from obtaining tax benefits through transactions that, while compliant with the literal wording of the Act, frustrate its object, spirit,...
Introduction The Canada Revenue Agency (CRA) recently announced its 100-Day Service Improvement Plan, running from September 2 to December 11, 2025. This initiative comes after months of mounting criticism about slow call centre response times, processing backlogs, and general difficulties Canadians have faced when dealing with the Agency. The...
Taxpayer Relief and the Limits of CRA’s Discretion Subsection 220(3.1) of the Income Tax Act authorizes CRA to waive or cancel interest and penalties when fairness requires. The CRA applies this provision through its taxpayer relief program in accordance with Information Circular IC07-1R1, Taxpayer Relief Provisions (August 18, 2017)....
Introduction The Federal Court’s recent decision in Spennie Holdings Inc. et al v. Attorney General of Canada (T-1197-25, released August 15, 2025) reaffirms established Canadian tax law. Taxpayers cannot circumvent the statutory appeal process in the Tax Court of Canada by filing judicial review applications in the Federal Court. This ruling...