Filing a Notice of Objection – The First Step in a Dispute with CRA

This article provides an overview of what is, for many taxpayers, the first step in a dispute with Canada Revenue Agency (“CRA”) – the “Notice of Objection”. For most people, dealing with their taxes entails gathering all their t-slips and other relevant information and handing it off to their accountant or doing it themselves at home. They receive an assessment, …

Capital vs Income

Many disputes arise over whether a gain from a sale should be treated as “business income” or “capital gain”. This is a common subject of tension between taxpayers and CRA because only half of a capital gain is taxable, while the full amount of business income is taxable. A common metaphor to illustrate the difference between the two types of …

Director Liability and the Available Defences

If you are a business owner who has chosen to incorporate, it’s likely that you are a director and officer of that corporation. Many owners don’t realize it, but directors are liable for the unremitted GST/HST of a corporation (pursuant to section 323 of the Excise Tax Act), and the unremitted source deductions of the corporation, including EI and CPP …

Gross Negligence

Canada’s self-reporting tax system relies on taxpayers to identify and report their income. Because of this, taxpayers are often confronted with the decision of how to report a certain stream of income – for example, whether a certain transaction should be treated as business income or capital gain, tax deductible or non-deductible or what proportion of a property is related …