Category Archives: Voluntary disclosures

Livaditis v Canada Revenue Agency, 2012 FCA 55, is an interesting case on voluntary disclosures. The cases reminds us that the CRA gets to decide when a disclosure is voluntary, and the courts will not interfere with such a decision … Continue reading →

A corporation withholds tax from a dividend that it pays to a non-resident and then fails to remit the amount withheld. The CRA later sends a letter to a shareholder of a shareholder of the dividend payor asking for information … Continue reading →