Tax & Trade Blog

---

COST AWARDS IN TAX LITIGATION

PROSPECTIVE TAX COURT LITIGANTS MUST UNDERSTAND COST RISKS

Download a PDF copy of this Blog here.

"Costs" are awarded to successful litigants in tax litigation, as in most forms of litigation, but are not well understood by the public. Indeed, many litigants may head to the Tax Court of Canada (“TCC”) without first understanding the rules behind cost awards and without contemplating how these "costs" awards work when on the losing end of the litigation and/or appreciating that they may well be on the hook for the government’s legal bills when they do lose.

---

LATE TAX OBJECTIONS FACE STRICT DEADLINES

NO SECOND CHANCES WHEN APPLYING FOR AN EXTENSION OF TIME TO OBJECT

Download a PDF copy of this Blog here.

A Notice of Objection (“NoO”) may be filed late – but ONLY if certain conditions and deadlines are met. Many taxpayers are unaware of the ability to apply for a late filing, and equally unaware that when THOSE deadlines are missed, it is all over!

---

REMEDIES CONSTRAINED IN JUDICIAL REVIEW

FEDERAL COURT CONFIRMS REDETERMINATION REMAINS USUAL REMEDY

Download a PDF copy of this Blog here.

An application for Judicial Review (“JR Application”) in the Federal Court can be an important tool for taxpayers to challenge decisions by the Canada Revenue Agency (“CRA”) that appear unreasonable, including decisions denying interest and penalty relief.

---

IGNORING CRA COULD LEAD TO JAIL!

COURT ISSUES 30-DAY JAIL THREAT TO TAXPAYER FOR NONCOMPLIANCE

Download a PDF copy of this Blog here.

We have previously written about Requests for Information ("RFI") issued to taxpayers under audit by the Canada Revenue Agency ("CRA") – and the importance of complying with CRA RFIs, with assistance from Experienced Tax Counsel.

---

TCC: NO EASY WAY TO PRE-PAY QUARTERLY GST

TAX AUTHORITIES WILL NOT AUTOMATICALLY APPLY SURPLUS TO INSTALLMENTS DUE

Download a PDF copy of this Blog here.

Quarterly GST/HST installments are a persistent administrative headache for many business owners. However, a recent Tax Court of Canada (“TCC”) decision proves there are no easy shortcuts around these recurring compliance duties.