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…
Taxpayers regularly argue that an administrative policy adopted by the Canada Revenue Agency (the “CRA”) constitutes an incorrect interpretation of the law that courts should reject. Courts sometimes side with these taxpayers, and choose not to follow the CRA’s administrative…
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…
“Rectification”, a means to “fix” a mistake made in the implementation of an agreement, has been a popular topic in tax law since the Supreme Court of Canada’s decisions limiting the availability of rectification for tax planning errors in AG…