Milgram Foundation v. Canada (Attorney General), 2024 FC 1405
Milgram Foundation v. Canada (Attorney General), 2024 FC 1405
The Applicant, the Milgram Foundation, was established in 1964 as a non-resident entity in Liechtenstein and had not filed Canadian tax returns prior to 2015. In 2015, the Foundation applied under the Canada Revenue Agency’s (“CRA”) Voluntary...
Practice Note No. 21 & the Rhetoric
Practice Note 21 & the Rhetoric
Practice Note No. 21 (dated November 30, 2018) is the Tax Court of Canada’s directive on how settlement conferences are to be handled. According to the Court:
1. Settlement conferences will not be scheduled unless...
DOJ Represents the Crown not CRA
Tax Law Services Portfolio - Memorandum of Understanding
The Department of Justice (DOJ) in Canada primarily represents the Crown, not the Canada Revenue Agency (CRA) as an independent entity. How it works:The CRA is a federal agency responsible for tax administration.When legal matters arise (such as tax disputes or...
CRA Reprisal Complaint – Form RC459
Understanding Reprisal Complaints Against the Canada Revenue Agency (CRA)
Canada Revenue Agency (“CRA”) employees have enormous individual discretion facilitated by the law. It was only relatively recently that Canadians were able to complain to a third-party, a service complaints division. Before that complaints were...