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Posts filed under: Reassessments

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 »

The Problem with Penalties

The Canada Revenue Agency seems more and more willing to impose penalties for all sorts of perceived transgressions. We've talked about penalties in a previous blog post ( ). One that seems to be a trap for the unwary and can be very unfair is the penalty for… more »

Is Your Trust Valid?

Trusts have become very popular over the last 20 years.  Many families have established trusts to take advantage of income splitting or multiplying the $750,000 lifetime capital gains deduction so that each member of the family can take advantage of it.  Living trusts, alter ego trusts and joint spousal or… more »

Tax Problems with Salaries for Spouses and Children

Businesses are only required to pay income tax on their net income, which allows businesses to deduct expenses including wages, salaries and benefits. Family-owned and operated businesses will often pay salaries to family members for services provided to the business. In some cases, the business owner will use salaries as… 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 »

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 »