Audits

CRA Audits & TFSA Penalties Audits of Tax Free Savings Accounts - Louie v. Canada, 2019 FCA 255 (CanLII) Tax-Free Savings Accounts (“TFSA”) are regularly audited by the Canada Revenue Agency (“CRA”). One reason being is that there are opportunities to abuse the “tax free” element beyond the...

Cameco - Can CRA force a Taxpayer to attend an In-Person Oral Interview during a CRA Audit? NOTE: 2021 Federal Budget change nullifies this decision… Canada (National Revenue) v. Cameco Corporation, 2019 FCA 67 (CanLII) In Cameco, the Federal Court of Appeal...

S.245 - GAAR - The General Anti-Avoidance Rule The General Anti-Avoidance Rule (“GAAR”) is a catch-all provision found in section 245 of Part XVI of the Income Tax Act, RSC 1985, c 1 (5th Supp) titled “Tax Avoidance”. In short, GAAR provides the Canada Revenue Agency (“CRA”) with the broad power to object to a...