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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....more

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 changed its position on amounts previously excluded in calculating “salary...more

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 applied to discourage large corporations from objecting to tax assessments as a means of...more

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 March 20, 2013, the Federal Court issued its decision in Soft-Moc Inc. v. M.N.R. 2013 FC 291, dismissing...more

3/25/2013  /  Audits , Canada , CRA , Income Taxes
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