In the November issue of our series Tax Intelligence, we look at the relief options available to taxpayers who have neglected to file a tax return, want to disclose accurate or complete information without facing penalties or are seeking a waiver or cancellation of penalties and interest.
In the inaugural issue of our series Tax Intelligence, we discuss the important, and often misunderstood, issue of legal privilege in various forms, and its implications for communicating with your advisors.
On Friday, July 13, the Federal Court of Appeal released its decision dismissing the Crown's appeal in The Queen v. Sommerer, a case concerning the application of s.75(2), one of the oldest attribution rules in the Income Tax Act. On Monday, July 16, the Tax Court of Canada released its judgment allowing the taxpayer's appeal in Blackburn Radio Inc. v. The Queen, a case concerning whether consequential reassessments were statute-barred.
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