Information-gathering and tax audits by a revenue authority – could there be an ulterior purpose? *

Canada - May 10 2013
The Canadian Federal Court of Appeal's (FCA) recent judgment in MNR v RBC Life Insurance Co, 2013 FCA 50 (decided on 21 February 2013) condemned the…

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Voluntary disclosure under the Tax Administration Act *

South Africa - April 26 2013
The Tax Administration Act, No 28 of 2011 (TAA) provides for a permanent Voluntary Disclosure Programme (VDP) in ss225 - 233 (part B of chapter 16)…

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Understatement penalty: when can SARS potentially allege 'gross negligence' or 'intentional tax evasion'? *

Australia, South Africa - April 19 2013
The Tax Administration Act, No 28 of 2011 (TAA) introduces the 'understatement penalty' in Chapter 16. Section 223 contains an 'understatement…

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Understatement penalty: what does "reasonable care not taken in completing return" actually mean? *

South Africa - April 5 2013
The Tax Administration Act, No 28 of 2011 (TAA) introduces the 'understatement penalty' in Chapter 16. Section 223 contains an 'understatement…

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Reforming the taxation of trusts: a long time coming *

South Africa - February 27 2013
High Net Worth Individuals (HNWI's) and their use of trusts for tax and estate planning purposes go hand in hand. A trust is often praised for its…

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