Feigenbaum Law

Litigation

Money Laundering

Litigation

The Standard of Conduct the CRA Must Uphold in an Audit

Last week, we reviewed a decision in which the Canada Revenue Agency (CRA) was ordered to pay $5 million in damages after a court found that the Agency had engaged in a number of questionable practices during the “Billionaire’s Audit” targeting high net worth Canadians in the mid-2000’s. This week we explore the standard of conduct that ought to apply during any audit undertaken by the CRA. The Quebec Superior Court examined… Read More

Audit

Litigation

CRA Ordered to Pay $5 Million After “Unreasonable” Audit

The Canada Revenue Agency (CRA) was recently ordered to pay damages of almost $5 million after two men representing a group of taxpayers sued the agency claiming that the CRA engaged in “abusive” practices during an offshore tax audit which the men were caught up in. In a lengthy decision supporting the damages order, the Quebec Superior Court admonished the CRA for a number of questionable practices that took place during the… Read More

Offshore

Litigation

CRA Brings Loblaws to Court Claiming Offshore Corporate Tax-Avoidance

Proceedings between Loblaw Companies Ltd. (Loblaws) and the Canada Revenue Agency (CRA) began earlier this week in Tax Court. The CRA claims that Loblaws’ banking subsidiary has been used as part of a tax avoidance scheme. Depending on the outcome of the case, Loblaws may be liable for more than $400 million. The Details The CRA is alleging that Loblaws established Glenhuron Bank Ltd. (Glenhuron), a “phoney” bank in Barbados, in order to circumvent the… Read More