SpenceDrake Tax Law

05/14/2023

Nurses and personal support workers: A taxable or exempt supply?

Canada Revenue Agency (CRA) routinely targets staffing or employment agencies for audit. In the Tax Court of Canada appeal of A-Supreme Nursing & Home Care Services Inc. v. The King, [2023] T.C.J. No. 29, the dispute centered around a CRA audit of a staffing agency in the business of supplying h...

04/15/2023

In the decision of Watts v. The King, 2023 TCC 11, the Tax Court of Canada reiterated, at paragraph 58, that "with or without an assessment, the liability for the tax debt exists..." https://mondaq.com/Article/1300182

02/12/2023

Specified Foreign Property & Beneficial Ownership – Form T1135...

According to a decision of the Ontario Superior Court of Justice in Csak v. Aumon, 1990 CanLII 8070 (ON SC), at paragraph 8, a "beneficial owner is one who is the real owner of property...

01/25/2023

Imprisonment for Tax Evader not Rare Occurrence...

https://www.thelawyersdaily.ca/articles/42550/imprisonment-for-tax-evader-not-rare-occurrence?category=analysis

11/13/2022

Former Ontario Judge's Tax Shelter Donation Claim Fails In Tax Court - Crane V. The King, 2022 TCC 115 (CanLII): https://bit.ly/3Tx0NaC

10/29/2022

Employer Health Tax Disputes – An Overview: https://bit.ly/3DLQf2o

10/05/2022

https://www.mondaq.com/canada/tax-authorities/1235596/cra-net-worth-audit--challenging-necessity-and-methodology

According to the Tax Court of Canada in Ramey v. The Queen, 93 DTC 791 (Ramey), at paragraph 6, the "net worth method of estimating income is an unsatisfactory and imprecise way...

06/25/2022

Do Taxpayers Have To Physically Deliver Documents To CRA For Audit? https://bit.ly/3HPSUJa

06/15/2022

Admissibility of expert evidence in Tax Court considered in Yao v. Canada...
https://www.thelawyersdaily.ca/articles/37198/admissibility-of-expert-evidence-in-tax-court-considered-in-yao-v-canada?category=analysis

05/22/2022

https://www.thelawyersdaily.ca/articles/36432/executor-of-deceased-s-estate-fails-to-escape-personal-tax-liability-?category=analysis

Executors of the estate of a deceased can be held personally liable for its tax arrears. That is why it is important that a legal representative of the estate, such as an executor, obtain a clearance certificate from Canada Revenue Agency (CRA) before the disposition of estate assets.

04/06/2022

Get your taxes done at a free tax clinic ...
https://www.canada.ca/en/revenue-agency/services/tax/individuals/community-volunteer-income-tax-program.html

04/01/2022

CRA has been targeting staffing agencies and subcontractor expenses. A CRA auditor denied 100% of our client's Input Tax Credits for GST/HST paid on subcontractor expenses. With a Notice of Objection we recovered $555,932.62 of $684,890.81. We are contemplating a further appeal to recover the remaining $128,958.19

A boutique firm in downtown Toronto specializing in Tax Law.