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Dispute Resolution and CRA Audit Measures in 2021 Federal Budget

Anna Malazhavaya

Jun 8

Dispute Resolution and CRA Audit Measures in 2021 Federal Budget

Sharing a copy of the presentation tax lawyer Anna Malazhavaya with the help of articling student Alexandra Ilchuk made on April 27, 2021 to the members of the Taxation Section of the Ontario Bar Association. Unlike most posts on our blog, this presentation uses technical language (not plain language) and will be helpful to tax practitioners: tax accountants and tax lawyers. We discuss dispute resolution and CRA audit measures introduced in the 2021 Federal Budget, including:

CRA Can Now Compel Oral Interviews

Anna Malazhavaya

May 26

CRA Can Now Compel Oral Interviews

I never met anyone who said they enjoyed being interviewed by an auditor with the Canada Revenue Agency. For sure, CRA audits can be stressful and disruptive to a business, but this is the price we pay to maintain the integrity of our tax system. The CRA’s audit powers are already quite broad and now they are about to expand even further. Anyone who must file a tax return in Canada (and, therefore, can be audited) should pay attention. The 2021 Federal Budget announced on Ap

This taxpayer bought and sold 5 houses in 6 years. The Tax Court decided on his tax liability.

Anna Malazhavaya

Sep 17, 2020

This taxpayer bought and sold 5 houses in 6 years. The Tax Court decided on his tax liability.

While I avoided detailed case commentaries on my blog to date, the recent Tax Court of Canada's decision in Hansen is too interesting to miss. In this case commentary, we will discuss: - when (how far back) the CRA has a right to reassess a taxpayer; - what facts the courts may consider when determining a taxpayer's intention when buying real estate; - when bad professional advice is better than no professional advice; and - how the CRA can discredit your testimony by calling

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