“Rectification”, a means to “fix” a mistake made in the implementation of an agreement, has been a popular topic in tax law since the Supreme Court of Canada’s decisions limiting the availability of rectification for tax planning errors in AG…
I last wrote about the decision in BP Canada Energy Company v. Canada (National Revenue), 2017 FCA 61 on April 10, 2017. In that decision the Court imposed important restrictions upon the use of the s.231.1(1) audit powers by…
The Income Tax Act provides CRA with broad powers of administration and enforcement. In BP Energy Company v. Minister of National Revenue, 2017 FCA 61, the appeal court considered the authority to conduct the inspection of books and records given…
The BC government recently congratulated itself on the apparent effects of its controversial decision over the summer to impose an additional 15% property transfer tax on purchases of real estate in Metro Vancouver by foreign buyers. Since then, the…
If a year is to end with something that causes a bang, then the decision in Minister of National Revenue v. Iggillis Holdings Inc. and Ian Gillis Et Al., 2016 FC 1352 did just that. In reasons that are ambitious,…
Finance Minister Bill Morneau has released a consultation paper on certain tax planning strategies that involve the use of private corporations. The paper focuses on the following three issues identified in Budget 2017: (1) sprinkling income using private corporations;…
In Grimes v. The Queen, the Tax Court of Canada recently awarded costs above the Tariff to a taxpayer who was partly successful in an appeal turning on the determination of the fair market value of shares, and ordered…
On July 11, 2017, the OECD Committee on Fiscal Affairs released the draft contents of the 2017 update to the OECD Model Tax Convention. The 2017 update primarily comprises changes to the OECD Model Tax Convention that have been…
The CRA has released Draft IC00-1R6 – Voluntary Disclosure Program for discussion purposes only. If published in its current form, IC00-1R6 would drastically alter the existing scope and parameters of the CRA’s voluntary disclosure program.
Draft IC00-1R6 here: https://www.canada.ca/en/revenue-agency/campaigns/ic00-1r6-voluntary-disclosures-program.html
The CRA boasts increased reporting, compliance and audit measures in support of its commitment to protecting the fairness and integrity of the Canadian tax system, as it relates to ensuring a healthy and stable housing market.
Read more here:
