SimpsonWigle Law LLP Tax News

You know it must be the season because the CRA has issued another warning about investing in tax shelters. (more…)

Two courts of appeal have recently considered attempts to litigate personal income tax disputes outside the Tax Court of Canada. Smith et al v. Canada (Attorney General) et al, 2006 BCCA 237, and The Queen v. Roitman, 2006 FCA 266, show that it is quite difficult to resolve a dispute with the CRA otherwise than by proceeding to Tax Court. That said, the decisions seem to leave open the possibility that one could sue the CRA for a liability arising out of fraudulent CRA conduct (see ¶27 of Roitman).

The CRA has been “archiving” certain of its Interpretation Bulletins and Information Circulars, which prompted one of our readers to ask “What does it mean when an IT or IC has been ‘archived’ or ‘cancelled’”? I wasn’t exactly sure myself, and so I wrote to the Income Tax Rulings Directorate in Ottawa to inquire further. The following is its response: (more…)

Yesterday, the Federal Court of Appeal released its decision in M.N.R. v. Redeemer Foundation, 2006 FCA 325, which overturns the decision of the Federal Court in Redeemer Foundation v. M.N.R., 2005 FC 1361 (see my article on the latter case). (more…)

From a Department of Finance press release circulated earlier today:

Businesses throughout Ontario will benefit from one tax return, one set of rules and one point of contact as a result of a corporate income tax collection agreement signed today by Canada’s New Government and the Government of Ontario.

The capitals on “New Government” are a nice touch. You can find a copy of the memorandum of agreement here.

I have added a new permanent article to the site on audits and objections. A link to the new article can also be found in our sidebar. The article is a sort of prequel to my article on Tax Court procedure. Both articles are really aimed at my clients: they are a convenient way to educate them about CRA and Tax Court procedure, which, at times, can bewilder the best of us.