Greg DelBigio, K.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 »
There can be no doubt that the intentional suppression of sales data, whether through use of an electronic device (often referred to as a “zapper”) or through use of an eraser on the end of a pencil might constitute criminal…
In his Blog posting “Finance Releases Proposed Amendments” (15 July 2013), my colleague Ian Gamble discussed several of the legislative proposals recently made by the Minister of Finance.
The proposals also include suggested amendments to s.241 of the Income Tax Act…
The following blog was co-written by Greg DelBigio and Leah Plumridge:
The Canada Revenue Agency (“CRA”) now has easier access to confidential taxpayer records as a result of a recent British Columbia Supreme Court decision, Canada Revenue Agency v.…
The following blog was joint collaboration by Greg DelBigio, David Thompson, James Murdoch, and Steve Cook:
Last week saw tax law become the subject of international headlines. Media outlets excitedly announced that as a result of a “leak” of documents the…
Two important features of the 2013 Budget, released last week, are the closing of tax “loopholes” used for “aggressive” tax planning and renewed focus upon measures to investigate and prosecute tax evasion.
In the words of the government:
“To help…
I was on an airplane last week in order to escape from the interminable Vancouver rain. As I contemplated the warmer and drier climate that would receive me, I also used the flight as a chance to catch up on…
In Anchor Pointe Energy Ltd. v. the Queen, 2007 FCA 188 the Court held “[i]t is trite law that, barring exceptions, the initial onus of proof with respect to assumptions of fact made by the Minister in assessing a taxpayer’s…
A recent newspaper article described a criminal prosecution commenced by the United States against a Swiss Bank. The charge alleged that the bank provided secret bank accounts to US citizens for the purpose of assisting those account holders in the…
The following blog was co-written by Greg DelBigio and Natasha Reid:
In a presentation made to members of the Canadian Bar Association Tax Subsection in November of 2011, the CRA provided statistics and information on the application of third-party advisor…