What kinds of cases are you looking for?    < Previous Case Collections — holding off on collecting on incorrect GST/HST assessmentGST/HST — Advertising servicesGST — air travel commissionsGST — builder built home for personal useGST — builder of new home was not who CRA thought it wasGST/HST — Cancelling interest on "wash transaction"GST — cleaning up years of failure to charge GST on management feesGST — community centre constructionGST/HST — convincing CRA that it was too late to assessGST — corporation providing health care servicesGST/HST — credit for net tax wrongly remittedGST — dental clinicGST — directors' liability (car dealership)GST — directors' liability (company dissolved)GST — director's liability (construction contractor)GST — director's liability (corporate lawyer)GST — directors' liability (person never agreed to be a director)GST — directors' liability (public company)GST — director's liability (restaurant owner)GST — directors' liability assessment — individual was 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miscellaneous adjustmentsGST/HST — new housing rebateGST/HST — net tax refund approvedGST/HST — no "substantial renovation" of apartment buildingGST — partnership assessment was out of timeGST — purchase of real estateGST/HST — purchases by President as agentGST — rebate for ship towed out of the countryGST/HST — rebate to builder of student residenceGST — recognizing when a second objection had to be filedGST/HST — recovering HST not paid on sales incentivesGST/HST — recovering tax from customers after CRA assessmentGST — reducing assessment by almost 90%GST/HST — reducing assessment on self-supply of new homeGST — registrants were not associatedGST — reopening audit after expiry of appeal periodGST — retroactively deeming a business to be GST-registeredGST — sales of condominiumsGST — school board's liability eliminatedGST — services to insolvent companies were zero-ratedGST/HST — services to US company were zero-ratedGST/HST — services were zero-ratedGST — stopping a client from being driven out of businessGST — summer camp teaching English as a second language was exemptGST — tax on purchase of commercial propertyGST — tire installer neglecting to bill GSTGST — townhouse renovationsGST/HST — valuation of student residenceGST — voluntary disclosure — negotiating interest relief and income tax offsetGST — voluntary disclosure acceptedGST — voluntary disclosure of GST collected on commercial rentsGST — voluntary disclosure of management feesGST — waiver of interestGST — waiver of interest and penaltyGST — waiver of penaltyGST — wash transactionGST — were courses educational or recreational?PST — director's liabilityPST — directors' liability (car dealership)PST — directors' liability re data conversion projectPST — eliminating assessment for tax collected by franchisorPST — invoices written up incorrectlyPST — reducing tax on sale of book with CD-ROMPST — refund of tax on supermarket constructionIncome tax — $2 million payment on retirement was tax-freeIncome tax — another refund where return filed lateIncome tax — assessment for transfer by tax debtorIncome tax — auditor demanding too muchIncome tax — builder built home as personal residenceIncome tax — cancelling source deductions assessmentIncome tax — capital gains vs. incomeIncome tax — charitable donation of kidney beansIncome tax — charitable donation to US religious schoolIncome tax — child support deductionIncome tax — claiming business losses from past yearsIncome tax — companies were not carrying on Personal Services BusinessIncome tax — corporation was bare trusteeIncome tax — costs of mother's Notice of Objection deductibleIncome tax — CRA chasing widow for deceased's RRSPIncome tax — deduction for Power of Attorney feesIncome tax — donations to suspect charity allowedIncome tax — expenses against unreported incomeIncome tax — expenses of setting up a film shelterIncome tax — general anti-avoidance ruleIncome tax — getting the $500,000 capital gains exemptionIncome tax — 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expensesCollections — execution preventing sale of propertyPayroll withholdings — directors' liability (company dissolved)Payroll withholdings — directors' liability (public company)Payroll withholdings — penalty for late remittanceYour problem goes here Next Case > GST — reducing assessment by almost 90% My client was the sole director of a company that carried on a heating contracting business. The company was late in filing its GST returns, and two years of its records were destroyed when my client's truck caught fire (he had the records in his truck because he was taking them to a new accountant). My client's accountant asked the CRA what to do, and was told to refile based on the previous year's filings for which there were records. Two years later, the business was audited by the CRA. The auditor used the company's bank deposit records, and assessed the company for some $255,000, including penalty and interest going back over 10 years. The company was now inactive and had no assets, but my client could be liable as a director for the company's GST debt. Accordingly, I filed a Notice of Objection for the company. I demonstrated that the auditor's calculations were wrong in various ways. First, a calculation of GST based on bank deposits should be 7/107ths of the deposits, not 7%. Second, there were numerous deposits that were transfers of money from my client's other bank accounts, when the company needed money, and thus did not represent taxable sales. Third, the company was entitled to input tax credits for GST paid on expenses. Normally one needs the original invoices to be able to claim input tax credits, but the invoices had been lost in the truck fire. I was able to show that the expenses had indeed been incurred, and from one major supplier I obtained copies of their invoices to my client's company, which fortunately had not yet been discarded even though they were over 10 years old. I demonstrated, based on my published commentaries which had been approved by the Tax Court of Canada, that my client did not need to have the invoices now as long as we should convince the CRA that he did have them at some point in the past. I also demonstrated that the ITCs allowed should be 68% of sales, rather than the 30% allowed by the auditor. Finally, I provided detailed evidence showing that the company had stopped carrying on business as of a particular date, so that all deposits to the bank account after that date were either account transfers or deposits on behalf of another company. The CRA appeals officer asked for more information, and in discussions with him, I managed to get him to increased the allowable ITCs to 72% of the sales. He agreed with all of my submissions, and reduced the GST owing on the assessment to about $28,000. The client, who was no longer facing the loss of his home and all his assets, was delighted with the outcome. (2005)