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Monthly Archives: January 2009
Process
The CRA and the Crown like to say (or at least sometimes they act as if), in the objection and Tax Court appeal process, all that matters is whether the assessment in issue is correct. Justice J.E. Hershfield, in Wood … Continue reading
Posted in Cases, Tax Court Appeals
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Failure to File Penalty
Subsection 162(2.1) of the Income Tax Act provides for a penalty for a non-resident corporation that fails to file a return and that it is liable to a penalty under subsections 162(1) or (2). The penalties provided by the latter … Continue reading
Posted in International
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De-registered
The CRA has revoked the status of two more charities that had participated in tax shelters.
Posted in Cases, Charities and Not-for-Profits
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Insurance
The taxation of insurance policies is a world of its own, and in my experience not many advisers seem able to explain that world clearly. The virtue of White v. The Queen, 2008 TCC 414, an informal procedure case, is … Continue reading
Posted in Cases, Individuals
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Lipson
The Supreme Court released its decision in Lipson today: see Lipson v. The Queen, 2009 SCC 1. The CanLII link to the case appears to be down right now, but it’ll probably be fixed later.
Posted in Cases, Individuals
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Limitation Periods
The following article appeared in the latest edition of the Hamilton Law Association Law Journal. The Income Tax Act (Canada) (the “Act”) contains numerous limitation periods that affect when the Canada Revenue Agency (the “CRA”) can issue an assessment to … Continue reading
Posted in Objections, Tax Court Appeals
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