As we have blogged here and here, the CRA has “third-party” transfer powers that allow it to follow a taxpayer’s GST or income tax debts to relatives where it can demonstrate that money or assets have been diverted to those relatives, for less than fair market value.
A better alternative would be dealing with one's tax debts during one's lifetime, and using the CRA’s newly revamped Voluntary Disclosure Program to help settle one’s tax affairs finally and effectively.
The Tax Court of Canada's (“TCC”) recent decision Ballantyne v. The King (2025 TCC 127) underscores the mess that can be created for a spouse or children if tax debts remain unaddressed.
After COVID, the CRA seems to be really ramping up its audit activities, both for GST/HST and income tax matters. Once a Notice of Assessment is issued, reversing the CRA’s position becomes an uphill battle as the Objection and Appeal processes are technical and complex.
This blog focuses on the Objection and Appeal processes under the Excise Tax Act (the “ETA”), highlighting common pitfalls and the need for a strategic approach in tax disputes.
When a person (whether a corporation or natural individual) crosses a border to perform services, Canada and the US have detailed taxing rules, aimed at ensuring that the person entering the other country properly reports those activities. These rules often come with mandatory “withholding taxes“ on the payer of the services resident in the country where the services are being performed.
Canada has recently fine-tuned its position on Regulation 105 withholding, which may come as a surprise to many involved in the cross-border provision of services.
