Articles

CRA Voluntary Disclosure Program

Apr 22, 2016
Cardinal in Early Spring

The Canada Revenue Agency’s Voluntary Disclosure Program promotes voluntary compliance with Canada’s tax laws by encouraging taxpayers to come forward and correct deficiencies in their tax filings on a penalty exempt basis. This paper provides an overview of the existing Voluntary Disclosure Program, analyses the programs current use and argues in favour of amendments to…

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The Due Diligence Defence

Mar 21, 2016
Chain Lock

What is due diligence and why is it important? “Due diligence” is a context-specific determination referring to the level of judgment, care, prudence, determination, and activity with which a person would reasonably be expected to act. In business dealings, establishing due diligence – that you, as either an officer or a director of the corporation…

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How to Set up a Co-operative

Mar 7, 2016
Muskoka Lake

A cooperative or “co-op” refers to an incorporated business organization owned by members sharing common needs or goals. Incorporation presents a number of advantages to its members, namely the co-op’s separate legal existence, limited liability for the members, and general agreement to basic principles on how the organization will operate.

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The Decline of the Successful Tax Shelter

Feb 23, 2016
Sunflower

This essay reviews the Income Tax Act (Canada) (the “Act”) tax shelter provisions and provides an overview of relevant issues to demonstrate that despite criticisms that the provisions and Canada Revenue Agency (“CRA”) enforcement are overreaching, it has been successful in prohibiting, preventing and reassessing participants in aggressive tax shelter programs. It argues that issues…

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