In correspondence released October 10, 2012 (2012-0455781E5), the CRA said it has the power to reassess a dissolved Ontario company. This stems from s. 242(1)(b) of the Business Corporations Act (Ontario), which provides that a civil, criminal, or administrative action…
One of the simplest business structures involves one party (typically a company) holding legal title for and on behalf of the true beneficial owner (in a group). This can be done for various reasons, both tax and non-tax related. The…
An appeal to the Tax Court from an assessment must be filed within specific time limits. As a general rule, the notice of appeal must be filed within 90 days of receiving the Minister’s notification confirming the assessment. Subsection 165(3)…
There are various reasons why an individual might decide to give up residence in Canada; most of them are not tax driven. Canada’s tax rates are favourable compared to those in most developed countries and changes in family circumstances and…
On Wednesday, the Canada Revenue Agency (CRA) released correspondence (2012-0436921I7) between Headquarters and a Large File Case Manager in a local office (TSO). Under audit was a Canadian parent company (Canco), which had invested in USD preferred shares of a…