After COVID, the CRA seems to be really ramping up its audit activities, both for GST/HST and income tax matters. Once a Notice of Assessment is issued, reversing the CRA’s position becomes an uphill battle as the Objection and Appeal processes are technical and complex.
This blog focuses on the Objection and Appeal processes under the Excise Tax Act (the “ETA”), highlighting common pitfalls and the need for a strategic approach in tax disputes.
When a person (whether a corporation or natural individual) crosses a border to perform services, Canada and the US have detailed taxing rules, aimed at ensuring that the person entering the other country properly reports those activities. These rules often come with mandatory “withholding taxes“ on the payer of the services resident in the country where the services are being performed.
Canada has recently fine-tuned its position on Regulation 105 withholding, which may come as a surprise to many involved in the cross-border provision of services.
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