The CRA is expected to soon commence audit activities to review payments made pursuant to three of Canada’s COVID-19 relief programs: the Canada Emergency Wage Subsidy (“CEWS”), the Canada Emergency Response Benefit (“CERB”), and the Canada Emergency Student Benefit (“CESB”).…
The recent Federal Court decision in Canada (National Revenue) v. Hydro-Québec, 2018 FC 622 made a strong statement against an interpretation of the CRA’s powers that would allow virtually unlimited invasions of taxpayer privacy. The decision considered the scope of…
In Burlington Resources Finance Company v. The Queen, 2017 TCC 144, Madam Justice D’Auray considered a motion brought by the Crown to compel the Appellant to answer certain questions that were refused during an examination for discovery. In the…
The Honourable Marshall Rothstein, Q.C., who served on the Supreme Court of Canada from March 2006 to April 2015, spoke at a special meeting of the CBA Tax Section (BC Branch) on April 14, 2016. During his time on the…
When a taxpayer enters into an agreement with the CRA in the course of an audit of a particular taxation year, the taxpayer likely expects that the CRA will not come back to audit and reassess that same year again.…
A recent case out of the Federal Court is causing a stir in the tax community. In Canada (National Revenue) v. Revcon Oilfield Constructors Incorporated, 2015 FC 524, Mr. Justice Mosley made the following statements, which might suggest that…