The Canada Revenue Agency’s Voluntary Disclosure Program: Current Processing Issues
The Canada Revenue Agency’s Voluntary Disclosure Program (VDP) has gone through a number of organizational changes over the past few years. For […]
Cheryl Gibson
Provincial Income Allocation: Salaries and Wages to Include All Taxable Benefits
In the Provincial Income Allocation Newsletter No. 4 (March 2013), the Canada Revenue Agency notes that the Allocation Review Committee (“ARC”) has […]
Tax Court of Canada Appeal of Large Corporation Thwarted by Wording of Objection
Since 1995, the Large Corporation Rules found in subsections 165(1.11), 169(2.1) and 152(4.4) of the Income Tax Act (Canada) have […]
Foreign-based Requirement Under Section 231.6 of the Income Tax Act Upheld by the Federal Court
The Canada Revenue Agency had an important win this week in its efforts to access information outside of Canada. On […]