Category Archives: Objections

Case update

Posted on January 25, 2007 by John Loukidelis

On February 1, I will be speaking to the CRA practitioner’s group at the Royal Botanical Gardens about “Tax Cases of Interest”. I have written here about all of the cases on which I will present. The following table lists … Continue reading →

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Anchor Pointe

Posted on December 4, 2006 by John Loukidelis

The CRA’s Appeals branch, according to P148 (“Resolving Your Dispute: Objection and Appeal Rights Under the Income Tax Act”), exists “to resolve disputes arising from decisions made under legislation administered by the [CRA] by conducting fair and impartial reviews.” In … Continue reading →

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Audits and Objections

Posted on October 4, 2006 by John Loukidelis

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 … Continue reading →

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Fees, audits, objections and appeals

Posted on July 13, 2006 by John Loukidelis

When can a taxpayer deduct fees paid to contest an assessment or reassessment? As is usual in tax matters, the answer is neither simple nor obvious.

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Cautionary Tale

Posted on December 19, 2005 by John Loukidelis

Rajah v. The Queen, 2005 TCC 637 is not a case that breaks new ground, legally, but it serves as a useful reminder — expressed with the usual clarity and concision that one finds in Mr Justice Bonner’s decisions — … Continue reading →

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CRA Obligations to Disclose Audit Files

Posted on November 21, 2005 by John Loukidelis

In Scott Slipp Nissan Ltd. v. Canada (Attorney General), 2005 FC 1477, the Federal Court held that section 295 of the Excise Tax Act did not authorize the Minister to refuse to disclose portions of an audit report merely because … Continue reading →

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Arguing with the CRA While the Clock Ticks

Posted on September 9, 2005 by John Loukidelis

You file an income tax return for your client, and later the CRA issues an assessment or a reassessment that does not agree with the return as filed. Your natural instinct is to try to solve the problem by discussing … Continue reading →

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The Perils of Large Corporation Appeals

Posted on August 25, 2005 by John Loukidelis

When drafting a notice of objection for a large corporation, it is essential to ensure that you cover all of the issues in dispute between your client and the CRA. If you fail to cover all of the issues, your … Continue reading →

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