Feigenbaum Law

CRA

Audit

Corporate Tax Planning

CRA Targeting Contractors Buying Supplies at Hardware Stores in New Audit

We’ve previously blogged about various actions the Canada Revenue Agency (CRA) has taken to crackdown on alleged tax evasion in particular industries, including in the bar and restaurant industry. This week, we continue our blog series by looking into a new audit the CRA is undertaking. This time, the agency is undertaking a review into general contractors and those working in the home improvement sector.  This new audit represents the latest in a… 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

Charter challenge

Litigation

Ontario Man Accused of Tax Fraud After Alleged Child Tax Credit Scheme

An Ontario man is facing allegations of tax fraud after allegedly claiming more than $60,000 in child tax credits for more than forty fictitious children. What Happened? The 39-year old man is facing four charges under the Income Tax Act. According to the Canada Revenue Agency, the man unlawfully claimed child tax benefits by “making, participating in, assenting to, or acquiescing in the making of a false or deceptive statement” to obtain Canada Child… Read More

Corporate taxes

Corporate Tax Planning

CRA Report: Canadian Companies Avoided Billions in Taxes

According to a report recently released by the Canada Revenue Agency (CRA), Canadian corporations avoided around $11 billion in corporate taxes in 2014 (between $2.7 billion and $3.5 billion for small companies, and between $6.7 billion and $7.9 billion for bigger companies). The report marks another measure in a series of actions taken by the CRA to look into tax avoidance by corporate and personal tax-payers in Canada, as we’ve previously written about. Read More

Audit

Tax Disputes & Litigation

Cameco Awarded More than $10 Million in Legal Fees After Decade Long Dispute with the CRA

Canadian resource company Cameco, one of the world’s largest producers of uranium fuel, recently announced that it would be receiving $10.25 million in costs after a protracted battle with the Canada Revenue Agency (CRA) over alleged tax evasion. Some Background The dispute began when the CRA questioned Cameco’s corporate structure following the company’s reorganization in the late 1990’s. At issue was whether Cameco used a Swiss subsidiary, Cameco Europe Ltd. (CEL) as a means of… Read More

Federal election

Corporate Tax Planning

CRA Successful in Appeal of $1.7 Million Malicious Prosecution Case

We’ve previously blogged about a ground-breaking decision in which the B.C Supreme Court ordered the Canada Revenue Agency (CRA) to pay more than $1 million in damages for the malicious prosecution of two British Columbia business owners who the agency had claimed had engaged in tax evasion. Since then, the CRA appealed that decision, and the B.C. Court of Appeal recently overturned it. Now, after more than a decade-long battle with… Read More

Cryptocurrency

Bitcoin

Canada Revenue Agency Auditing Cryptocurrency Investors

Last year, we wrote about how Bitcoin and other cryptocurrency is treated by the Canada Revenue Agency (CRA) for tax purposes and what impact an investment in crypto might have on a Canadian taxpayer’s taxes.   Now, crypto and the CRA are back in the news as the agency continues to finesse its approach to digital currency and adapt to rapidly changing realities. According to a cryptocurrency journalist writing for Forbes magazine,… Read More

Office towers seen from below

Corporate Tax Planning

Canada’s Biggest Loyalty Points Company Facing Significant Tax Reassessment

A Canada Revenue Agency (CRA) audit of Montreal based Aimia Inc. (Aimia) has concluded. Aimia, which is responsible for customer loyalty programs worldwide, may now be facing a large tax bill. Aimia – An Overview Aimia Inc. which describes itself as a “global data-driven marketing and loyalty analytics company” providing “clients with the customer insights they need to make smarter business decisions” and also “partner[ing] with companies to help generate, collect and… Read More

Restaurant

Corporate Tax Planning

CRA Reveals Continued Crack Down on Restaurant Industry

CBC News reported this week that the Canada Revenue Agency (CRA) will be reviewing data on beer, wine, and liquor sales in an attempt to crack down on tax avoidance in the bar and restaurant industry.  As we blogged about earlier this year, this is not the first time that this sector has come under scrutiny. High-Risk Sector The CRA has said that it has identified the restaurant industry… Read More

Corporate taxes

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