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Our tax lawyers help Canadian taxpayers resolve tax disputes with the Canada Revenue Agency effectively and efficiently. learn more »

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About PM's Tax Law Group

An increasingly complex tax system creates new challenges for individuals and businesses every year. learn more »

Archives for October 2011

Fixing a Mistake

One of the main jobs of the Canada Revenue Agency (Revenue Canada) is to ensure that the proper amount of tax is assessed on transactions such as a sale of property or a sale of shares. But what happens if Revenue Canada misinterprets the transaction and thinks that you have done… more »

Fighting the Imposition of Gross Negligence Penalties

The Canada Revenue Agency can impose gross negligence penalties in addition to the assessment of tax. Gross negligence penalties are imposed under subsection 163(2) of the Income Tax Act. Under the Income Tax Act gross negligence penalties are determined with reference to the amount of tax owing: gross negligence penalties are 50% of… more »

Taxpayer Relief: CRA’s Discretion is Clarified

The Canada Revenue Agency has the discretion to cancel penalties and interest assessed to a taxpayer. Applications for relief from interest and penalties are made under the taxpayer relief provisions of the Income Tax Act. Until recently, the CRA took the position that it could only exercise its discretion where the application for… more »