On July 13th, 2012, the Federal Court of Appeal dismissed the Crown’s appeal in The Queen v Peter Sommerer (2012 FCA 207).
The facts are not complex. In 1996, Peter Sommerer’s father, Herbert Sommerer, created an Austrian private foundation of…
The Canada Revenue Agency (the “CRA”) has confirmed that a large scale information gathering project is underway in respect of not-for-profits (NPOs) and their income-generating activities. Between 2010 and 2013, Specialty Audit is coordinating the audit of 1440 randomly selected…
The Canada Revenue Agency (“CRA”) has recently mailed detailed audit request letters to members of certain individual pension plans (“IPPs”). The letters appear to be connected to an ongoing audit program targeting IPPs.
As background, an IPP is a defined…