David Davies is a partner with Thorsteinssons LLP. He enjoys challenging CRA administrative practice and policy, preferring instead to rely on the law. Read complete profile »

Author: David Davies

Taxable TFSAs

Published by David Davies

Almost since Tax-Free Savings Accounts (TFSAs) were first introduced in 2009, the Canada Revenue Agency (CRA) has been intent on clamping down on what it views as inappropriate activities undertaken within TFSAs. One area in particular has raised the ire…

TFSA Audits Continue

Published by David Davies

It’s early 2015 and the CRA continues to aggressively audit Tax-Free Savings Accounts (TFSAs), going as far back as 2009 when TFSAs were first introduced. And why not? There is typically no time limit on issuing these types of assessments.…

Double the Jeopardy

Published by David Davies

Normally, the CRA cannot collect any amount of reassessed income tax, interest or penalties while the reassessment is under objection or appeal (although CRA can collect half the reassessed amount, if the taxpayer is a large corporation). However, if there…

Making the Crime fit the Punishment

Published by David Davies

The Federal Court of Appeal’s recent decision in The Queen v. Guindon attempts to answer the question: when is an intentional action criminal in nature? In Guindon, the taxpayer signed 153 charitable donation receipts in what was characterized by the…

CRA Expands Audits of Tax-Free Savings Accounts (TFSAs)

Published by David Davies

We have reported previously on the audit initiatives of the Canada Revenue Agency (CRA) with respect to Tax-Free Savings Accounts (TFSAs) (http://www.thor.ca/tax-alerts/punitive-tfsa-audits/ and http://thor.ca/blog/2012/11/cra-begins-issuing-tax-free-savings-account-tfsa-reassessments/). Recent discussions and correspondence with the CRA suggest a significant expansion of those audit…