Apparently, the Ontario Medical Association has opened a law firm. It is offering to incorporate professional corporations for doctors for a “nominal” fee ($100 plus disbursements plus GST for a total of $523.90). It is unclear how long this sale will last, so doctors should hurry to take advantage of it before it is too late. (more…)
What tax practitioner hasn’t woken up in the middle of the night, sweating, because of dreams haunted by section 84.1 file demons? I will try to banish the demons — or propitiate them anyway — in a short presentation on February 2, 2006 at the CRA’s Hamilton & District Tax Consultation Group. (more…)
A taxpayer submits a fairness request to the CRA, and the request is rejected by the first officer to review it on the ground that it did not show inability to pay. The taxpayer agrees with the officer: the taxpayer did fail to show inability to pay because the taxpayer never raised the issue! The taxpayer, however, did mention CRA delay as a ground for relief, but that point is not addressed by the officer. The taxpayer sends the request back to the CRA for another review. A recent case — Dort (Estate) v. Canada (Minister of National Revenue), 2005 FC 1201 —- suggests that this other review should be regarded as a “first look” by the CRA and that, if the CRA rejects the request, the taxpayer is entitled to a second review. (more…)
Here’s a depressing case to start off the New Year and take us into the “RRSP season”: Nunn v. The Queen, 2005 TCC 806. The CRA warning about similar schemes, discussed here and here, was apt but too late for Mr Nunn apparently.
