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CRA Sham Investigations Target Telcos
Oct 24 2022 - As we blogged about here and here, CRA has recently focused its audit powers to investigate allegations of shams (i.e., fraud) in the application of GST in the telecommunications industry. The alleged fraudulent activities come in many forms and can...
https://www.taxandtradelaw.com/Tax-Trade-Blog/cra-sham-investigations-target-telcos.html -
A Cautionary Tale: Objection Extensions
Oct 24 2022 - Tax professionals are well aware of how critical it is to file Notices of Objection on time — generally within 90 days of the mailing of a Notice of Assessment. For professionals and taxpayers who find themselves unable to have met this deadline, sec...
https://www.taxandtradelaw.com/Tax-Trade-Blog/a-cautionary-tale-objection-extensions.html -
No Privilege for Tax Accountants!
Oct 24 2022 - Lawyer-client relationships enjoy what is commonly referred to as solicitor-client privilege – or lawyer-client privilege. Regrettably (and surprisingly to some), accountants do not have this protection! As the recent Federal Court of Appeal (“FCA”...
https://www.taxandtradelaw.com/Tax-Trade-Blog/no-accounting-tax-confidentiality.html -
CBSA Initiates Re-Investigation re: Concrete Rebar (RB1)
Oct 05 2022 - On September 8, 2022, the Canada Border Services Agency (“CBSA”) issued a notice that it would be conducting a re-investigation in respect of certain concrete rebar originating in or exported from Turkey (RB1). Responses to the CBSA’s Request for Inf...
https://www.taxandtradelaw.com/Tax-Trade-Blog/cbsa-initiates-re-investigation-re-concrete-rebar-rb1.html -
New PST Rules for BC Online Marketplaces
Sep 30 2022 - British Columbia’s (“BC’s”) new PST rules regarding online marketplaces have been in effect for about three months now. First announced in the 2022 provincial budget, the provincial government claims the changes will close tax loopholes and “better a...
https://www.taxandtradelaw.com/Tax-Trade-Blog/new-pst-rules-for-bc-online-marketplaces.html -
Luxury Tax Update – How SLITA Works in Practice
Sep 14 2022 - On September 1, 2022, the Select Luxury Items Tax Act (“SLITA”) officially came into effect. Vendors and importers of subject goods should be registered with the Canada Revenue Agency (“CRA”), paying tax, and keeping track of the information the...
https://www.taxandtradelaw.com/Tax-Trade-Blog/luxury-tax-update-how-slita-works-in-practice.html -
Does the CRA consider you to be a commercial builder? Maybe!
Jul 07 2022 - As we have blogged about several times in the past, homebuilders are frequently in the gunsights of CRA in hopes of capturing potentially unremitted GST/HST on sales made the course of their commercial activity. A less-explored issue is how CR...
https://www.taxandtradelaw.com/Tax-Trade-Blog/does-the-cra-consider-you-to-be-a-commercial-builder-maybe.html -
Carousel Schemes: Don't Let CRA Take You for a Ride!
May 25 2022 - It seems that the only thing hotter than inflation these days is CRA’s auditing and assessments in missing traders, carousel schemes and shams. Affected industries so far include telecom, gold and precious metals, diamonds and precious gems – and eve...
https://www.taxandtradelaw.com/Tax-Trade-Blog/carousel-schemes-dont-let-cra-take-you-for-a-ride.html -
US "First Sale"? Not in Canada! (& Other Issues Back in Vogue)
May 20 2022 - The primary customs valuation method across the Western world is “transaction value”, which is a way of valuing goods coming across international borders. Transaction value is used by both the US Customs and Border Protection Agency (CBP) and the Can...
https://www.taxandtradelaw.com/Tax-Trade-Blog/us-first-sale-not-in-canada-other-issues-back-in-vogue.html -
Draft Luxury Tax Legislation Released!
Apr 11 2022 - After our February blog post, the Department of Finance finally released draft legislation for its “luxury tax” on vehicles, aircraft and vessels (“items”). Assuming it is passed, the Select Luxury Items Tax Act (“SLITA”) is scheduled to come into fo...
https://www.taxandtradelaw.com/Tax-Trade-Blog/draft-luxury-tax-legislation-released.html -
The Luxury Tax: Missing in Action?
Feb 09 2022 - As previously discussed in our Customs & Trade Blog, the Government of Canada (“GoC”) has been preparing a “luxury tax” on cars/trucks, personal aircraft and personal boats. The luxury tax was initially proposed in the 2019 Liberal Party of Canad...
https://www.taxandtradelaw.com/Tax-Trade-Blog/the-luxury-tax-missing-in-action.html -
Kingstreet Remedy – A special relief for Taxpayers!
Dec 08 2021 - Public law (or restitutionary) remedies are usually relied on as a last resort by taxpayers facing CRA assessments. They are last resorts because they are only available in exceptional circumstances, and the CRA almost never applies them, while the C...
https://www.taxandtradelaw.com/Tax-Trade-Blog/kingstreet-remedy-a-special-relief-for-taxpayers.html -
No Progress With CRA Objections? – Read this!
Nov 24 2021 - A CRA Audit is often a lengthy and tedious process, but if an assessment is ultimately issued, that can be its own uphill battle! CRA’s dispute resolution process – also referred to as the Notice of Objections (generally “Objections”) process – often...
https://www.taxandtradelaw.com/Tax-Trade-Blog/no-progress-with-cra-objections-read-this.html -
No Relief Against Collections Actions – Hammer out a deal!
Oct 13 2021 - Judicial review applications for injunctive relief attempting to circumscribe or prohibit the CRA’s collections powers are usually doomed to failure – the test requires a high threshold to meet! Such matters must be dealt with immediately on audit, a...
https://www.taxandtradelaw.com/Tax-Trade-Blog/no-relief-against-collections-actions-hammer-out-a-deal.html -
WCO Prompts Amendments To Canada’s Customs Tariff in 2022!
Oct 04 2021 - The World Customs Organization (“WCO”) revises its Nomenclature of Harmonized Commodity Description and Coding System used for the uniform classification of goods traded internationally (“Harmonized System” or “HS Codes”), every five years. This is d...
https://www.taxandtradelaw.com/Tax-Trade-Blog/wco-prompts-2022-amendments-canada-s-customs-tariff.html -
CRA Ramping up Audits of Large Corporations
Aug 26 2021 - After suspending most audits for the early part of 2020 due to the COVID-19 pandemic, the Canada Revenue Agency (the “CRA”) has been slowly but steadily gearing up its audit activity through 2020 and the first half of 2021. This is expected to contin...
https://www.taxandtradelaw.com/Tax-Trade-Blog/cra-ramping-up-audits-of-large-corporations.html -
Beware the Director's Liability Assessment!
Aug 18 2021 - As with have blogged about many times in the past (see here, here, here, and here), one of the most misunderstood areas of the law around corporate directors is the concept of director’s liability for the corporation’s unremitted tax. Several recent...
https://www.taxandtradelaw.com/Tax-Trade-Blog/beware-the-director-s-liability-assessment.html -
Canada Consulting on New Luxury Tax for 2022!
Aug 16 2021 - In Budget 2021 the Government of Canada proposed a “luxury tax” effective January 1, 2022 on sales of certain luxury vehicles – cars/trucks, aircraft, and boats - whose selling price exceed a $100,000 threshold for cars/trucks and aircraft, and a $25...
https://www.taxandtradelaw.com/Tax-Trade-Blog/canada-consulting-on-new-luxury-tax-for-2022.html -
Interest & Penalties Apply On “Net Tax” (GST/HST)
Aug 04 2021 - The Canada Revenue Agency’s (“CRA”) administrative position on computation of interest and penalty for late-filed GST/HST returns has been that it applies on “all amounts outstanding” (notwithstanding possible available refunds, rebates or input tax ...
https://www.taxandtradelaw.com/Tax-Trade-Blog/interest-penalties-apply-on-net-tax-gst-hst.html -
Visa Card Intermediaries Exempt From GST/HST
Jul 14 2021 - The Canada Revenue Agency (“CRA”) has been rigorously challenging intermediaries in the financial services industry, categorizing their services as taxable promotional, advertisement or taxable administrative services (as opposed to treating them as ...
https://www.taxandtradelaw.com/Tax-Trade-Blog/visa-card-intermediaries-exempt-from-gst-hst.html