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By Drache Aptowitzer LLP | 4 Minutes Read November 16, 2016

CRA provision misuse: The right to remain silent

Practically every tax professional in the country has had to deal with the situation which arises when the Canada Revenue Agency (CRA) bases its reassessing position on the basis of an oral comment to the CRA. The difficulty is that there is no proof the comment was made or it may have been the result of a misunderstanding between the parties. In our practice we had one instance where a comment by an official of a charity to the CRA served as basis for reassessing over a thousand taxpayers. While the official admitted to having made the comment the fact was that the CRA auditor had misunderstood the context in which it was made.

Article by Drache Aptowitzer LLP / Business, Finance and Accounting, Payroll / Canada Revenue Agency, CRA, CRA auditors, Income Tax Act, meeting with the CRA, section 231.1 of Income Tax Act, statement made to CRA, Tax Court of Canada, tax professional

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