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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...

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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...

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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...

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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...

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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...

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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...

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Good News for Farmers: Supreme Court of Canada Clarifies Proper...

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...

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Directors’ Liability for Corporate Tax Obligations

The Board of Directors of a company are responsible for making decisions for the company. The directors manage or supervise the management of the business and affairs of the company.  The directors are...

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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...

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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...

View Article

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...

View Article

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...

View Article

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...

View Article


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...

View Article

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...

View Article


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...

View Article

Good News for Farmers: Supreme Court of Canada Clarifies Proper...

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...

View Article


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...

View Article

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...

View Article
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