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Recent Posts
Below is a preview of the five most recent posts from the blog SimpsonWigle LLP Tax News. To read these posts in their entirely or subscribe to future updates from this blog, please visit their website!
Reason and the T1135?
May 19th, 2012The Tax Court has vacated penalties for failing to file a T1135 on time for a year where tax was otherwise not payable. See Douglas v R, 2012 TCC 73, a decision of Justice Woods under the informal procedure. Read more »
Savoy Now Somewhat Shabby
May 19th, 2012I wrote here about Savoy v R, 2011 TCC 35. The Federal Court of Appeal recently concluded that Savoy was wrongly decided on the question of what the Minister must do to satisfy the requirements of subsection 227.1(2) where a … Continue reading →... Read more »
Voluntary disclosure legal fees
May 19th, 2012In a recent technical interpretation (2012-0434071E5), the CRA confirmed that legal fees incurred to prepare a voluntary disclosure application are not deductible under paragraph 60(o) of the Income Tax Act. Paragraph 60(o) permits the deduction of “amounts paid by the … Continue reading... Read more »
Access to information
May 9th, 2012PWC has just published a good Tax Memo (2012-27) on taxpayer access to audit and appeals reports and other documents generated by the CRA in the course of issuing a reassessment. I found helpful the references to P-148 and CRA … Continue reading →... Read more »
Involuntary VD
May 4th, 2012Livaditis v Canada Revenue Agency, 2012 FCA 55, is an interesting case on voluntary disclosures. The cases reminds us that the CRA gets to decide when a disclosure is voluntary, and the courts will not interfere with such a decision … Continue reading →... Read more »
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