Tax Notes

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November 2014

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Administrative Changes to Canada Revenue Agency’s Voluntary Disclosure Program

Rahul Sharma

Introduction The Canada Revenue Agency’s (the “CRA’s”) voluntary disclosure program permits taxpayers to disclose information not previously reported to the CRA in relation to the taxes payable by them for a prior taxation year. Taxpayers may also rely on the...

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Surplus Stripping Limits Clarified

Although the taxpayers were largely unsuccessful in the case of Descarries v. R., 2014 TCC 75, the decision of Tax Court Judge Hogan J. provides a useful analysis of the limits to be applied to “surplus stripping” and contains much that is...

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Displaying 1-2 of 2