Below are matters we have resolved for clients. Every case turns on its own facts, and past results do not predict the outcome of any future matter.
$1,000,000 director liability assessment resolved at objection
We were retained by two directors of a corporation after they were assessed for over $1,000,000 relating to unremitted source deductions by a corporation. We resolved the matter completely after filing a Notice of Objection.
$550,000 third-party penalty taken to the Supreme Court of Canada
Our client retained us after being assessed a penalty of almost $550,000. We handled the matter from the Tax Court, through the Federal Court of Appeal and to the Supreme Court of Canada.
Stay obtained against revocation of a charity’s registration
After several attempts by a variety of different charities we obtained a stay for the revocation of a charity, at the time the first charity to do so.
CRA charity audits and revocation
Disallowed charitable donation receipts defended for a deceased donor’s estate
We were retained by the Estate of a deceased donor to a charity. While the charity was known to have engaged in some fraudulent receipting we managed to convince the CRA that there was no proof that the deceased donor had engaged in such activity.
Charity and not-for-profit law
Denied principal residence exemption on five homes in six years
Our client retained us after she was assessed capital gains tax on the sale of five homes in six years. After filing a Notice of Objection we showed that each of these sales was in fact legitimate and not in pursuit of business.
Art donation receipt settled at Tax Court after a decade of CRA delay
We were retained by donors of artwork to charity. The CRA disallowed the donation tax receipt and sat on the files for over a decade. We settled the matter at the Tax Court after filing a motion to strike the Crown’s pleadings.
Collections settlement that kept an operating business alive
We were retained after a corporate client who had fallen into difficult times but was then on its feet and was trying to catch up on its source deductions. The CRA attempted to shut down the organization but we negotiated a mutually agreeable settlement with the CRA.
Bankruptcy proposal renegotiated, organization still operating
Our client retained us after the CRA forced the organization to make a proposal in bankruptcy in order to settle its source deductions. At that stage we were able to negotiate a mutually agreeable settlement and the organization is functioning strongly today.
GST/HST assessment against a charity rescinded in full
Our client retained us after the CRA and Revenue Quebec assessed this charitable organization as being a business. After one letter and a five year consideration of the issue by the CRA, the CRA agreed with our view and completely rescinded their assessment.
Charity and not-for-profit law