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Voluntary disclosures (“VDs”) are permitted for Canadian tax purposes under the Canada Revenue Agency’s (the “CRA”) Voluntary Disclosures Program (the “VDP Program”), and their importance is highlighted by a recent case where the CRA reached back into history to assess a taxpayer prior tax exposure.

CRA Power to Reassess Beyond Limitation Periods

Typically, the CRA can reassess a taxpayer within four years for GST/HST matters and three years for income taxes:  see paragraph 298(1)(a) of the Excise Tax Act (the “ETA”);  see subsection 152(3.1) of the Income Tax Act (the “ITA”).

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The United States, Mexico and Canada have enjoyed near-complete free trade since the inception of the North American Free Trade Agreement (“NAFTA”) in 1994.  In fact, Canada and the US have enjoyed “free trade” even longer than that, since the inception of the first Canada-US Free Trade Agreement in 1989.  Unfortunately, free trade amongst the “three amigos” is not guaranteed!

In this blog we explore the mandatory Review and Term Extension Rules in the US-Mexico-Canada Agreement (“USMCA” – also known in Canada as the “CUSMA”), and what it is going to take in order to keep our vibrant North American trade relationship going!

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On March 20, 2024, Public Safety Canada (“PSC”) released updated guidance (“Guidance”) on the application of the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the “FCLA”).

While PSC’s update is aimed to provide clarity, it left many ambiguities, particularly regarding the definitions of “consolidated financial statements”, “asset” and “control”.  These terms play a critical role in determining whether a foreign entity may fall within the reporting requirements of the FCLA.

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