Notice of Objection

Notice of Objection & Voluntary Disclosures Program The ability to file a Notice of Objection to Notices of Re/assessment issued following a Voluntary Disclosure, governed by IC00-1R6-Voluntary Disclosures Program (“IC00-1R6”), was limited to specific circumstances. Importantly, taxpayers could not file a Notice of...

Devon Canada Corporation v. Canada, 2015 FCA 214 Devon Canada Corporation v. Canada, 2015 FCA 214 (CanLII) concerns the scope of what comprises a Notice of Objection under the Large Corporation Rule in subsection 169(2.1). The Federal Court of Appeal (“FCA”) held that the reference to “notice of objection” in subsection...

Swift v. The Queen, 2020 TCC 115 & Coates v. The Queen, 2011 TCC 74 & GST/HST In Ontario, for example, many taxpayers bought and/or renovated homes consecutively during the housing upturn. Consequently, it has been common for Canada Revenue Agency (“CRA”) to target the consecutive purchase and sale of 3 or 4 homes...

CRA Collections When taxpayers fall behind on their tax obligations, the Canada Revenue Agency (CRA) has broad powers to collect outstanding amounts. Whether you are an individual or a business, understanding the CRA’s collection process is critical to protecting your financial interests and resolving tax debts...

New CRA Policy on Gross Negligence Penalties for SR&ED Claims The Canada Revenue Agency (CRA) has updated its enforcement approach for Gross Negligence Penalties under subsection 163(2) of the Income Tax Act, affecting Scientific Research and Experimental Development (SR&ED) claims. Effective January 28, 2025,...

Preparing for an Informal Procedure Tax Court Hearing Taking your tax dispute to the Tax Court of Canada is a significant step. Whether you’re filing under the informal or general procedure, proper preparation is critical to ensuring your case is presented...

Disagreements with the Canada Revenue Agency (CRA) can arise from audits, reassessments, or penalties. Whether it’s a personal tax issue or a business-related matter, CRA disputes can be stressful and complex. Without expert guidance, you may face significant financial and legal consequences. COMMON REASONS FOR CRA DISPUTES CRA disputes often...

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:...

Selling your home can be an exciting milestone, but it can also attract the attention of the Canada Revenue Agency (CRA). Homeowners often rely on the principal residence exemption to shelter capital gains from the sale of their principal residence from taxes. However, when CRA audits a property sale, it will challenge the claim of this...

In Canada, the obligation to report income accurately to the Canada Revenue Agency (CRA) is not just a legal requirement but a cornerstone of our tax system. However, instances of unreported income can arise due to various reasons, sometimes inadvertently, leading to potential legal implications with the CRA. Understanding Unreported Income...