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 »
About Thomas Fellhauer
Tom’s practice includes a wide range of tax law matters including tax planning, company law, corporate reorganizations, trusts, estate planning and succession planning for family businesses for clients. 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 »
About Pushor Mitchell Tax Group
When disputes arise we have considerable experience in dealing with the Canada Revenue Agency and in representing clients in income tax and GST appeals. 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 »
About Pushor Mitchell Tax Group
When disputes arise we have considerable experience in dealing with the Canada Revenue Agency and in representing clients in income tax and GST appeals. more »