Information About Building NewLaw Podcast

Key Takeaways Richard Homburg claimed a deduction that would have cut the tax on his $1.16 million stock option benefit in half. The CRA said his control and influence over the company meant Homburg was not entitled to the deduction. How a business describes itself before a tax dispute matters. Homb … Read more »

Bill C-31 gives the CRA more power and a greater advantage in tax disputes. At audit, it adds a notice of non-compliance with daily penalties and suspends the reassessment period while a notice is outstanding. At the Tax Court, it doubles the amounts heard under the Informal Procedure, where there i … Read more »

Key Takeaways The result was fixed before Chobham Corporation Ltd. filed its Notice of Appeal. In many cases, the Tax Court can overturn a reassessment; this was not that kind of case. Internal agreement that a reassessment is unfair feels like a winning argument. It isn’t. The Trust’s whole case wa … Read more »

A tax opinion answers a narrower question than most readers assume. Some of the limits are written into the document — in its assumptions, its scope section, its definitions paragraph, and its date. These are the parts read least. Nothing in the opinion, or in the file behind it, records who supplie … Read more »

 A tax plan is moving toward implementation. The tax opinion has been delivered.  The first question is whether the filing position is defensible. A tax opinion may answer that question and stop there. However, a conclusion that a filing position is defensible does not necessarily address how the po … Read more »