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New Limits Upon 231.1(1) Audit Powers

Canada - April 10 2017 The Income Tax Act provides CRA with broad powers of administration and enforcement. In BP Energy Company v. Minister of National Revenue, 2017 FCA…

Managing The Audit of Real Estate Transactions

Canada - October 11 2016 It used to be that the favorite topic of conversation in Vancouver, and then more recently in Toronto was the cost of real estate. There was unending…

Ken Jiang, Noah Sarna.

New Protections for Solicitor-Client Privilege and New Restrictions on the Use of 231.2 ITA Requirements

Canada - July 8 2016 I have had many hours of spirited conversation with my friend and colleague, Craig Sturrock Q.C., over the extent to which, or the way in which the…

Budget 2016 - A New Focus on the Investigation of Tax Evasion

Canada - March 29 2016 As part of Budget 2016 the government announced that it is "committed to preventing underground economic activity, tax evasion and aggressive tax…

Tax Fraud, Money Laundering and the Consequences of a False Voluntary Disclosure

Canada - March 25 2016 A spring break holiday provides one with a good opportunity to catch up on reading and to reflect upon basics. In this instance, the reading was the…