Conclusion: the Minister and her agent the CRA can suck in some years and blow in others. This complicates tax planning and is something that I often find myself explaining to clients. It doesn’t matter that [filing position X] was accepted in prior years, or that the CRA did not take issue with [filing position X] in other audits or reviews, each year is a fresh game, with new rules, and new audit risks. When working on a tax plan, it is prudent to always turn your mind to preparing an audit file to defend each and every filing position.
Read MoreOn Tuesday April 28th, the Liberal government suggested it will prohibit entities "who evade or avoid tax" from receiving aid. Yesterday, it wavered. See my commentary on effecting such a limit on relief, as quoted in the Toronto Star article: Justin Trudeau's Position on COVID-19 Bailouts for Tax Haven Companies Gets Murkier.
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