Feigenbaum Law

CRA

Legal fees

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

Malicious prosecution

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

Reassessment- 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

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

Money Laundering

Personal Tax Planning

Canadians with Disabilities Face Challenges in Obtaining Disability Tax Credits from the CRA

Over the last several months, the difficulties that disabled Canadians have been having in dealing with the Canada Revenue Agency (CRA) and obtaining their disability tax credit (DTC) have been making headlines. Earlier this year, Global News reported that an estimated 1.8 million Canadians live with a severe disability, but only 40% of them have been accessing the federal disability tax credit (DTC). Part of the reason for this are what the news outlet… Read More

Sports & Entertainment

Prominent Canadian Olympic Athletes Owe Millions in Back Taxes

According to the Canada Revenue Agency, Donovan Bailey, who won the Gold Medal for the 100m sprint at the 1996 Summer Olympics in Atlanta, Georgia, owes approximately $2.3 million dollars in unpaid taxes. Kate Pace Lindsay, who competed in three Winter Olympics and was ranked number one downhill skier in the world in 1993 also owes significant sums to the government. Both athletes were advised by the same tax lawyer. What Happened? The Toronto Star… Read More

Northern

Personal Tax Planning

Government to Review “Abnormal” Number of Tax Audits of Taxpayers in Northern Canada

CBC News reported this week that Northerners living in Nunavut have been overly reassessed (i.e. audited) on their income taxes. National Revenue Minister Diane Lebouthillier visited Iqaluit in April to meet with territorial and business leaders. A prominent topic of discussion during the meetings was the number of Nunavut residents (Nunavummiut) who are reassessed on an annual basis. Since then, Lebouthillier has promised to take a closer look at this matter and… Read More