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The Tax Court of Canada and the Informal Procedure

When facing a tax dispute with the Canada Revenue Agency (CRA), the idea of taking the matter to the Tax Court of Canada might seem daunting. However, for smaller disputes, the Tax Court offers an informal procedure that is simpler,

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Accountant, Client and Legal Privilege

Coopers Park Real Estate Development Corporation v. The King, 2024 TCC 122   Accountant-Client privilege does not exist. However, under what circumstances could information or documents from an accountant or third-party be considered privileged and confidential in a legal proceeding?

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Section 85 Rollovers

Incorporating a business can be a powerful step toward growth, but it often comes with significant tax implications. Fortunately, the Income Tax Act offers Section 85 rollovers, a valuable mechanism allowing business owners to transfer assets into a corporation without

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Bare Trusts: A Simple Guide

In the world of tax and estate planning, various trust structures can help manage and protect assets. One such structure is the bare trust. Although bare trusts may seem simple, they offer unique advantages and considerations that can benefit individuals

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Offshore Audits: What You Need to Know

Offshore Audits: What You Need to Know In recent years, the Canada Revenue Agency (CRA) has ramped up its focus on offshore tax compliance, leading to a significant increase in offshore audits. These audits are designed to ensure that Canadians

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The Principal Residence Exemption

The Principal Residence Exemption The principal residence exemption is a significant tax benefit in Canada, shielding homeowners from capital gains tax when they sell their primary home. However, for a property to qualify for this exemption, it must meet certain

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The Power to Audit is the Power to Destroy

The authors of this article address the serious problem of lack of effective recourse for Canadian taxpayers where they are subject to the abusive exercise of audit and/or assessment powers by tax officials: The-Power-to-Audit-is-the-Power-to-Destroy-Judicial-Supervision-of-the-Exercise-of-Audit-Powers.pdf

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