Articles 2021

The ongoing debate about international tax avoidance (often referred to as base erosion and profit shifting, or “BEPS”) and international response such as the OECD’s BEPS Action Plan (July 2013) have focused on mainly income tax. BEPS is providing both the impetus and potentially a key missing ingredient to tackle the persistent challenge of collecting sales tax on e-commerce.

The article provides a review of the ingredients required for a partnership to exist; with a focus on the “carried on in common” requirement.

The taxpayer in Academy of Applied Pharmaceutical Sciences v. R. relied on representations of an auditor regarding a method for properly allocating between GST/HST exempt and non-exempt services. At issue, therefore, was the application of the doctrines of estoppel and officially induced error.

The article: (i) provides an overview of Canada Revenue Agency’s voluntary disclosure program; and (ii) highlights certain recent changes regarding the administration of the program.

The article provides an overview of new legislation that requires all international electronic funds transfers of $10,000 or more to be reported to the Canada Revenue Agency.

The recently released Canada Revenue Agency document 2014-0519701I7 sets out the CRA’s position regarding whether the Minister of National Revenue can refuse a nil or substantially incomplete income tax return filed under ss. 150(1) of the Income Tax Act.

The importance of controlling the litigation process and making the right decisions at the outset of every case.

“I swear it’s not my fault”: An Update on the Due Diligence Defence to a Director’s Liability Assessment under Canadian Tax Statutes.