Feigenbaum Law

Tax Disputes & Litigation

A vintage photo of a window for a business where people could pay income taxes in NYC

Corporate Tax Planning

Report Indicates Staggering Number of High-Income Non-Filers in the United States

A recently released report from the United States’ Treasury Inspector General for Tax Administration (TIGTA) raised a flag concerning the Internal Revenue Service’s failure to pursue high-income earners who fail to file their taxes. Just how rampant is non-filing amongst high-income earners? The results of the study may be enough to raise eyebrows. How much money is lost due to non-filing? The report states that non-filing, which is a crime when… Read More

An alarm clock surrounded by numbers and a notebook representing new tax deadlines in Canada

Personal Tax Planning

Canada Revenue Agency Resumes Some Activities

Parts of Canada are slowly starting to return to normal. While much of the country is still grappling with the impact of COVID-19, courts and businesses have started to re-open. Similarly, the Canada Revenue Agency, which had largely ceased activities related to collections, audits, and appeals, has started to resume operations. This week we’d like to provide our readers with a summary of what activities have resumed and which are still… Read More

The coronavirus molecule

Litigation

The CRA and Tax Court During COVID-19

The current health crisis related to the spread of the coronavirus has created challenges and delays in a number of areas, at the height of the tax season in both Canada and the U.S. Many Canadians are left unsure of their obligations with respect to filing taxes in Canada, and when those filings will be assessed. Further, those facing scrutiny of current and past tax filings are no doubt wondering how these delays will impact… Read More

A closeup of a Mercedes Benz emblem

Corporate Tax Planning

A Tale of Three Cars

A requirement to use your own car at work can allow for associated expenses to be claimed on your income tax returns. However, not everyone is entitled to such claims (for example, you can’t make a claim if an employer already reimburses you), and it is critical to keep detailed records, especially if more than one vehicle is used for work. A recent decision from the Tax Court of Canada highlights… Read More

A man in a suit walking down a city street with luggage representing resignation from a job

Corporate Tax Planning

Company Director Escapes Tax Liability After Resigning

Being the director of a company might seem glamorous on the outside, but the role comes with a great deal of responsibility, including personal tax liability should the company find itself unable to comply with its tax obligations. A recent decision from the Tax Court of Canada looks at what is needed for a director to resign and avoid liability for a company’s tax debt. The debt The appellant was the… Read More

A person typing on a computer keyboard representing a charity donation scam

Tax Disputes & Litigation

Latest Appeal Unsuccessful In Huge Tax Scam

The latest step in a wide-ranging tax scam came last month when the Tax Court of Canada ruled against the appellant, a taxpayer who was caught involved in the scam. An article in the Globe and Mail described the decision as an aftershock of one of the biggest tax scams in Canada’s history. $30,526 in Tax Deductions The appellant was a retired autoworker who had claimed $30,526… Read More

An airplane in the sky representing a commercial pilot in tax dispute with CRA

Personal Tax Planning

Transferring Tax Debt in Addition to Money

Some people might go to great lengths to avoid paying a tax debt. One tactic that shows up from time to time is the transferring of cash or assets to a family member. A recent decision from the Tax Court of Canada serves as a helpful reminder that trying to escape a tax debt through these means can leave both the original tax debtor as well as their family member in… Read More

A man with a toolbelt representing a person acting as project manager in a dispute over GST/HST collection

Tax Disputes & Litigation

Contractor or Agent? A Crucial Difference When it Comes to Taxation

If there’s a lesson to be learned when it comes to contract law, it’s that language and details matter. Even a seemingly straightforward contract between two parties can lead to serious tax consequences if certain aspects of the business relationship are not properly addressed in the contract. In a recent case heard by the Tax Court of Canada, a taxpayer found himself in hot water after failing to collect HST during… Read More

An American flag against a blue sky

Tax Disputes & Litigation

American Business Owner Faces Penalties For Failing To Disclose Canadian Bank Accounts

We’ve had a number of blogs as of late discussing the United States’ Foreign Account Tax Compliance Act (FATCA). The legislation, introduced about ten years ago, empowers the IRS to pursue tax money from American citizens who have bank accounts in jurisdictions outside of the United States. Since the United States is virtually the only country in the world imposing taxation based on citizenship rather than residency, this means that Canadians who have… Read More

Tax laws

Tax Disputes & Litigation

Canadian Man Finds Unique Way to Challenge Tax Laws

A Canadian taxpayer recently found a unique way to challenge the Canada Revenue Agency (CRA) after the agency denied him the costs of a move from Whitby Ontario to Ottawa Ontario. After researching precendent-setting Tax Court decisions, the man ended up moving his belongings by packing them into a canoe and then paddling up the Rideau Canal. The Income Tax Act and Moving Expenses Under the Income Tax Act, (the Act), a taxpayer can claim moving… Read More