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Posts filed under: Uncategorized

Have You Been Mistreated By The Canada Revenue Agency?

Have you been treated badly by the CRA? Have CRA employees been rude to you? Have CRA employees treated you unfairly?  Have they bullied you? I am getting more and more clients coming to me with their “horror stories” about mistreatment at the hands of the CRA.  It seems to… 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 »

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 ( https://www.taxdisputehelp.ca/2011/10/fighting-the-imposition-of-gross-negligence-penalties ). One that seems to be a trap for the unwary and can be very unfair is the penalty for… more »

Are Adjusting Journal Entries Legally Binding?

If you are not familiar with accounting, adjusting entries are commonly made by accountants and bookkeepers to fix entries that were previously made with were incorrect or which adjusted the wrong accounts. For example, a payment by a business of a Visa bill might have included an airline and hotel… more »

Big Problems with Shareholder Benefits

Many small and medium sized businesses are incorporated. And most of those incorporated businesses are owned by one person, one family or a small group of owners. We call these closely-held private companies. When the Canada Revenue Agency audits a closely-held private company, they pay particular attention to transactions involving… 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 »

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 »

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 »