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Federal Court of Appeal Overturns Guindon Decision of Tax Court of Canada

We previously wrote about the Tax Court of Canada decision released on October 2, 2012, Guindon v. R., 2012 TCC 287 (“Guindon”).  The Guindon decision had dramatic implications for any Canadians who were assessed third party penalties pursuant to section 163.2 of the Income Tax Act (the “Tax Act”).  The decision… more »

Tax Court of Canada Finds That Third Party Penalties Are Criminal Sanctions

On October 2, 2012 the Tax Court of Canada released its decision in Guindon v. R., 2012 TCC 287 (“Guindon”). This decision has dramatic implications for any Canadians who have been assessed third party penalties pursuant to section 163.2 of the Income Tax Act (the “Tax Act”). If you have… more »

Good News for Farmers: Supreme Court of Canada Clarifies Proper Interpretation of Restricted Farm Loss Rules

This morning the Supreme Court of Canada released its decision in Canada v. Craig, 2012 SCC 43 (“Craig”). It’s good news for farmers, especially those farmers that need to work off the farm to make ends meet. Mr. Craig’s horse racing business incurred losses of $222,642 in 2000 and $205,655… more »

Applying for an Extension of Time to File a Notice of Objection

In my last post, I explained the deadline for Objecting to an Assessment/Reassessment and the process for applying for an extension of time to object if the initial 90 day deadline is missed.  A taxpayer has a right to dispute an Assessment/Reassessment by filing a Notice of Objection.  That right… more »

Deadline to Object

Deadline for Objecting to an Assessment/Reassessment A taxpayer has the right to object to a Canada Revenue Agency assessment of tax.  Objecting is the first formal step a taxpayer takes in disputing the assessment.  The right to object must be exercised within 90 days of the date the Notice of Assessment… more »

Supreme Court of Canada Releases GAAR Decision

On December 16, 2011 the Supreme Court of Canada (SCC) released its decision in Copthorne Holdings Ltd. v. Canada, 2011 SCC 63 (Copthorne).  The full decision can be viewed on the SCC Judgements website at  Copthorne involved the application of the General Anti-Avoidance Rule, or as it is… more »

How Can I be Assessed for Someone Else’s Tax Debt? – Section 160(1) Assessments

Receiving a tax assessment or reassessment from the Canada Revenue Agency (CRA) is often alarming. Imagine receiving a tax assessment that makes you liable to pay another person’s tax debt. Being assessed for someone else’s tax debt can be downright shocking. The CRA has a collection tool at its disposal… more »

How Far Back Can The CRA Go to Reassess Me?

Many clients ask me, “How long can the Canada Revenue Agency assess me for?” Or put another way, “How long until I am safe from a CRA reassessment for any given year?” In civil litigation the period of time that a person has to start an action is called the… 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 »