Greg DelBigio, Q.C. has advised and acted on behalf of individual taxpayers, corporations and tax advisors during audits, criminal investigations and after criminal charges have been approved. Read complete profile »
In Budget 2019, the federal government continues to bolster its tools and resources to detect and prosecute tax evasion and money laundering. These proposals are relevant both to those who do not pay the amount of tax the law requires,…
The Australian Taxation Office (ATO) recently announced that, through a consultation process, it is examining the use and, more particularly, what it says are occasions of misuse of claims of solicitor-client privilege. The Consultation is interesting but, it also provides…
Under the provisions of the Income Tax Act (the “ITA”), the CRA is authorized to inspect a taxpayer’s books and records and to require taxpayers to provide information and documents in the course of an income tax audit. However, the…
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…
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,…
It used to be that the favorite topic of conversation in Vancouver, and then more recently in Toronto was the cost of real estate. There was unending speculation on how high the prices might go and whether the party would…
I have had many hours of spirited conversation with my friend and colleague, Craig Sturrock Q.C., over the extent to which, or the way in which the Charter of Rights applies in tax law. In broad strokes, his position has…
As part of Budget 2016 the government announced that it is “committed to preventing underground economic activity, tax evasion and aggressive tax planning.” To achieve this, the budget proposes to allocate $444.4 million over five years to enable CRA to…
A spring break holiday provides one with a good opportunity to catch up on reading and to reflect upon basics. In this instance, the reading was the tax fraud prosecution of R. v. Khan and Muellenbach (2015 ONSC 7283) and…