2018 Federal Budget Highlights: 12 Changes Related to Taxation, the CRA, and you, the Canadian Taxpayer

The Federal Liberal government has just unveiled their 3rd budget, and in doing so will be increasing spending by roughly $20 billion dollars, bringing the federal deficit to roughly $670 billion dollars.

Looking at the tax issues, here are the main items which come from the budget this afternoon;

  1. 5-Week “Take-it-or-leave-it” Paternity Leave.

The government implemented a 5-week “take it or leave it” parental leave, pretty much like what Quebec has, in order to entice more dads to take paternity leave.  This would begin June 2019 (not sure why it takes this long to implement) and the Liberals expect it to cost taxpayers $1.2 billion dollars.

What this does not do is change the corporate culture which deters dads from taking time off, nor does it entice more moms to join the workforce.

What might have helped, would be more available daycare spaces, or fixing the Live-in Caregiver program which worked very well until it didn’t.

2.  Throwing bad money after bad money – Phoenix Pay system

If you have been following the Phoenix payroll fiasco that has been going on in the CRA, you would know that the CRA has already spent a lot of money on a payroll system which didn’t work, and then a ton of money to try and fix it.

Now, the Liberals have announced that it intends to eventually move away from Phoenix and explore the “next generation of the federal government’s pay system, but before doing so, the Liberals provided $16 million over the next 2 years to “research” a new pay system.

I’ll do that on my own, for half that amount.!

While “researching,” the CRA will now have $431.4 million over 6 years to try to fix the existing Phoenix system.

When you add the hundreds of millions of dollars that the Liberal government has already invested in fixing the Phoenix pay system, and the researching costs, and the budgeted costs, you will come to a figure of roughly $900 million on a system that this government will move away from.

This system was supposed to save the government roughly $70 million per year, starting in the 2016-17 fiscal year, and the Auditor General even said that scrapping the pay system would be the worst thing the government could do because if they start from scratch, they could have the same issues with another system!

3.  Help for the CRA to answer their phones!

The Liberal government is providing $206 million over 5-years to the CRA to help the Agency answer their phones.  This issue came up in November when the Auditor General noted that the CRA’s call centre only picked up the phone about one-third of the time.

The money will be used to improve the CRA’s telephone service, improve their online services and increase the number of community-based programs which help low-income people prepare their tax forms.  Ideally the call centre hours will also be expanded, and more training will be provided to ensure that more correct answers are provided.

4.  Private Company Passive Investment Income

Beginning taxation year 2019, there will be a phasing out of access to the small business deduction for Canadian Controlled Private Corporations (CCPC’s) which earn more than $50,000 of investment income.  The current rules for the refundable tax on dividends paid by CCPCs will also be amended.

CCPC’s are entitled to a preferential tax rate on up to $500,000 of qualifying active business income – the “small business deduction.”

Going forward, CCPC’s who earn income or net capital gains from property (not properties used in an active business) will be treated as follows; For each $1 of investment income earned over $50,000, the small business deduction limit will be reduced by $5, so once a CCPC has investment income greater than $150,000, they will lose their small business deduction entirely.

The government has decided that Canadians who earn income passively, ie/ rental income, deserve to pay more tax because either;

a. It’s not fair to Canadians who have to “work” to earn income

b. The Liberals got elected taxing the “rich” and by earning money this way – damn you – you are on their list, or,

c. The Liberals would tax a tax if they could because they need tax revenue to pay for all their promises.

5. New Tax Rules for Trusts to begin in 2021.

The government needs more taxes, hence the new tax reporting requirements for trusts which were unveiled in the budget.  The intention of these new rules is to provide the CRA with information related to beneficial owners, or potential beneficial owners of trusts.

Currently, trusts which do not earn income or make distributions in a taxation year are generally not currently required to file a T3 trust return.  (Trusts are required to file T3 returns if there is tax payable in the year or if the trust distributes income or capital to its beneficiaries.)

These new rules apply to express trusts which are resident in Canada as well as to non-resident trusts currently required to file T3 returns.  Each trust will have to provide the CRA with the identity of all of its trustees, beneficiaries and settlors, as well as each person who has the ability – through the trust terms or related agreements – to exercise control over trustee decisions regarding the appointment of income or capital of the trust, such as a protector.

The budget currently grants an exemption to mutual fund trusts, segregated funds, trusts governed by registered plans, graduated rate estates and qualified disability trusts, non-profit organizations and registered charities, and certain trusts that have been in existence for less than three months or that hold less than $50,000 in specified passive assets.

6. Tiered Partnerships Losses and At-Risk Rules

Essentially, partnerships wanted to use losses from one partner to lower the income of another partner, but the CRA disagreed.  The matter went to court and the CRA lost.  This budget reverses the CRA’s loss, making it a win, and worse than that, it is effective the date of the budget, which was February 27, 2018.  Losses are now lost.

7. Increased Assessment Period for CRA on Foreign Interests

Effective February 27, 2018, the CRA will have an extended reassessment period of taxpayers in respect of income arising in connection with foreign corporations in which they have at least a 10% interest in because it’s a long, often difficult process for the CRA to audit these foreign affiliates.

8. Reduced Filing Deadline to 6 Months for T1134.

Effective 2020, Taxpayers who currently had 15-months to file Form T1134, now have 6-months to do so.

9. Fighting Aggressive International Tax Avoidance

The Liberal government committed to fight international tax avoidance by strengthening rules related to controlled foreign corporations, addressing issues of treaty abuse, adopting the OECD revised Transfer Pricing Guidelines, and of greatest significance is the pledge to abide by tax reporting requirements of countries which Canada bilateral exchange agreements – and providing information to the tax authorities of these countries.

The acceptance of the OECD multilateral competent authority agreement now increases the countries which Canada can provide information to, and get information from.

Additionally, the CRA will be able to participate in what was called a “spontaneous exchange of information” on certain tax rulings with other tax administrations as part of a coordinated international effort to counter harmful tax practices.

The CRA also gets $38.7 million to expand its offshore compliance activities through the use of improved risk assessment systems and business intelligence, and to facilitate the hiring of additional auditors.

The anticipation is that the CRA will need these auditors to act on the new information they will be receiving as a part of the OECD/G20 Common Reporting Standard participation.

Another key tax issue relates to reassessment periods and non-residents of Canada to address a scenario where the CRA reassesses a taxpayer in order to reduce or eliminate a loss in a taxation year which results from a non-arm’s length transaction with a non-resident.  Currently, the CRA cannot reassess the taxation year to which that loss was carried back because the reassessment period has elapsed, but going forward, the CRA will have 6 years after the normal reassessment period to reassess the year to which the loss was carried back in such circumstances.

Another change impacts a scenario where a taxpayer contests a requirement for information (RFI) or an application for a compliance order – as this period will not be included when computing the time limit for the CRA to reassess.

This “stop-the-clock” rule is similar to the existing rule that applies for purposes of requirements for foreign-based information.


GST/HST is applicable on the fair market value of the management and administrative services provided by the general partner to an investment limited partnership where consideration becomes due or is paid before September 8, 2017.

GST/HST now applies to management and administrative services rendered by the general partner on or after September 8, 2017, unless GST/HST was charged by the general partner before that date.

The GST/HST is generally payable on the fair market value of management and administrative services in the tax year in which these services are rendered (however rules to calculate FMV, and what constitutes FMV were not provided at this time).

11. Excise – Cannabis Tax

A new excise duty framework for cannabis products under the Excise Act, 2001 applies to all products available for legal purchase, including fresh and dried cannabis, cannabis oils, and seeds and seedlings for home cultivation.

The cannabis taxation program will be administered by the federal government on behalf of most provincial and territorial governments on a coordinated basis. 75% of the taxation revenues from a combined $1 per gram / 10% of the price of the product, whichever is higher, excise duty rate will flow to participating provinces and territories, with the federal government receiving the remaining 25%.

12. Increased Funding to CRA and Tax Court of Canada

The budget provided money to the CRA and the Tax Court of Canada to:

  • $79 million over 5 years and then $15 million per year going forward in order to develop an electronic platform for processing trust returns;
  • $90.6 million over 5-years to help the CRA pursue domestic and international cases which have been identified as high-risk potential danger of loss through enhanced risk assessment systems;
  • $30 million over 5-years to enhance security measures aimed at better protecting the confidentiality of taxpayer information; and
  • $41.9 million over 5-year, and $9.3 million annually going forward to provide support for new front-line registry and judicial staff, most of whom are expected to support the Tax Court of Canada.

And so much more…



Canada Revenue Agency (CRA) Voluntary Disclosure Program (VDP) Changes March 1st, 2018.

The Canada Revenue Agency (CRA) have announced that effective March 1, 2018, changes will be made to the Voluntary Disclosures Program to narrow its eligibility criteria.

What is the Voluntary Disclosure Program (VDP)?

The VDP provides Canadians a second chance to change a tax return which has been previously filed with the Canada Revenue Agency (CRA), OR to file a return(s) which you should have filed with the CRA.

Your application under the VDP – if approved – allows you to file or amend a return without the CRA prosecuting you, or assessing penalties.

Who Can Apply?


Taxpayers can be;
• Individuals
• Employers
• Corporations
• Partnerships
• Trusts
• GST/HST registrant / claimants
• Registered exporter of softwood lumber products

You can apply, or you can have an authorized representative – like an accountant, or tax professional like inTAXicating, submit the application on your behalf.

How Many Times Can You Apply?

The CRA would prefer you use VDP once and stay up-to-date on filings from that point onwards, however should circumstances warrant it, you can apply again.

Conditions of a Valid Application

To qualify for relief, the application must:
• Be voluntary – You come to the CRA before the CRA gets to you.
• Be complete – You cannot file for one year, for example, you have to file everything and disclose everything.
• Penalty: Involve the application or potential application of a penalty and, for GST/HST applications, the application or potential application of a penalty or interest
• Time: Include information that is at least one year past due for income tax applications and, for GST/HST applications, at least one reporting period past due; and
• Include payment of the estimated tax owing.

The Process

Submit an application to the CRA, and if the CRA approves it, the returns in question are filed or amended and there is no penalties or fear of prosecution (unless you are engaged in criminal activities).

The CRA then expects you to pay the balance owing – or make arrangements to pay – because while there is no penalties, there is still interest accruing on the account.

* The above information applies until February 28, 2018.

The CRA will update their VDP guidelines as of March 1, 2018, so in order to be considered under the existing VDP, the CRA must receive your application, including your name, on or before February 28, 2018.

What Changes March 1st, 2018? 

On March 1, 2018, when the new VDP comes into effect, it narrows the eligibility criteria to access the Program and imposes additional conditions on applicants, making it more difficult for those who intentionally avoid their tax obligations to benefit from the VDP.

Income Tax Disclosures

With the changes to the program, two tracks will be created for income tax disclosures:

1. Limited Program

The Limited Program provides limited relief for applications that disclose non-compliance where the facts suggest that there is an element of intentional conduct on the part of the taxpayer or a closely related party.

Under the Limited Program, taxpayers will not be referred for criminal prosecution with respect to the disclosure and will not be charged gross negligence penalties, however, they will be charged other penalties and interest as applicable.

2. General Program

Under the General Program, taxpayers will not be charged penalties and will not be referred for criminal prosecution related to the information being disclosed. The CRA will provide partial interest relief for years preceding the three most recent years of returns required to be filed.

GST/HST, excise tax, excise duty, softwood lumber products export charge and air travellers security charge disclosures

For GST/HST, excise tax, excise duty, softwood lumber products export charge and air travellers security charge disclosures, three categories will be created:

1. Wash Transactions

Wash transactions are generally transactions where a supplier has failed to charge and collect GST/HST from a registrant entitled to a full input tax credit. This category provides relief only for applications involving GST/HST “wash transactions” that are eligible for a reduction of penalty and interest under the policy set out in GST/HST Memorandum 16.3.1, Reduction of Penalty and Interest in Wash Transaction Situations.

Registrants will not be charged penalties nor interest and will not be referred for criminal prosecution related to the information being disclosed.

A registrant must now disclose information on any non-compliance during the four years before the application is filed.

2. Limited Program

This category provides limited relief for applications that disclose non-compliance where the facts suggest that there is an element of intentional conduct on the part of the registrant or a closely related party.

Under the Limited Program, registrants will not be referred for criminal prosecution with respect to the disclosure and will not be charged a gross negligence penalty, however, they will be charged other penalties and interest as applicable.

3. General Program

All of cases fall under the General Program where registrants will not be charged penalties and will not be referred for criminal prosecution related to the information being disclosed.

The CRA will provide partial interest relief and a registrant must now disclose information on any non-compliance during the four years before the application is filed.

How to Determine if a Disclosure Falls under the General or Limited Program?

For both income tax and GST/HST disclosures, the determination of whether an application should be processed under the General or Limited Program will be made on a case-by-case basis and in doing so, the CRA may consider a number of factors, including but not limited to:
• The dollar amounts involved;
• The number of years of non-compliance; and
• The sophistication of the taxpayer/registrant.

Other Significant Changes to the VDP

1. Payment

Payment of estimated taxes owing: Payment of the estimated taxes owing will be required as a condition to qualify for the program (When a taxpayer does not have the ability to make payment at the time of filing the VDP application, they may request to be considered for a payment arrangement.)

2. Anonymous Disclosures Eliminated

The “no-names” disclosure method has been eliminated and replaced by a new pre-disclosure discussion service.

The process for taxpayers and authorized representatives to make disclosures on a no-names basis has been eliminated. Under the new “pre-disclosure discussion” service, taxpayers or their authorized representatives can have a conversation with a CRA official on an anonymous basis, but that discussion does not constitute acceptance into the VDP.

3. Large Corporations

Generally, applications by corporations with gross revenue in excess of $250 million in at least two of their last five taxation years, and any related entities, will be considered under the Limited Program.

4. Transfer-Pricing

Due to the complexity of transfer pricing issues, applications will now be referred to a specialized Transfer Pricing Review Committee, which will review the applications instead of the VDP.

For efficiency, taxpayers may send their applications directly to this committee.

5. Review by Specialists

Applications involving complex issues or large dollar amounts will be reviewed for completeness by the relevant specialist from the program area prior to being accepted.

6. Disclosure of Advisors

The name of the advisor who assisted with the non-compliance should now be included in the application.

7. Cancellation of Previous Relief

The new VDP regulations provide the CRA with the ability to cancel relief which was previous provided to a taxpayer if it is subsequently discovered that a taxpayer’s application was not complete due to a misrepresentation.

8. Mandatory Waiver of Rights of Objection and Appeal

Under the Limited Program, participants will have to sign a waiver of their right to object and appeal in relation to the specific issue disclosed.


If you need assistance with a Voluntary Disclosure – at any time – we can help!

Email: info@intaxicating.ca

On the phone: 416.833.1581 (If you are outside of Toronto, and would like to speak to us live, please email us, and we will gladly call you at your convenience)

On our website: http://www.intaxicating.ca (Portal coming soon – currently under construction).

Statute of Limitations for Tax Debt: Canada

Statute of Limitations for CRA Debts – Truth vs Myth

There is a common belief that there is a statute of limitations on tax debts and that taxpayers can ride out these periods and ultimately pay no taxes.  Google it, and you will see all kinds of information out there, but it’s the Canada Revenue Agencies information which matters the most.

A Collections Limitation Period (CLP) is the time in which the Canada Revenue Agency (CRA) can begin actions to collect a tax debt.

Myth: After the CRA issues a notice of assessment, it has either 6 years or 10 years to collect the debt. If you don’t pay what you owe within that time, the CRA can no longer collect the debt.

Fact: Each tax debt has a 6 or 10 year collections limitation period (depending on the tax) and the limitation period can be restarted or extended by the CRA when certain events occur.  At that point, the total amount of time that the CRA has to collect the debt will be longer than 6 or 10 years.

Even after the collections limitation period ends, you can still have a tax debt and interest will continue to accrue until the tax debt is paid in full.


Start of the collections limitation period

The limitation period starts on the date that a notice of assessment or reassessment is sent, or 90 days after that date, depending on the type of tax debt.


Types of tax debt

The collections limitation period start date and duration will be different depending on the type of tax debt. Some tax debts are subject to collections restrictions, while others are not.

The following are some of the most common types of tax debt:


Individual (T1)

The Collections Limitation Period (CLP) starts on the 91st day after the CRA issues the notice of assessment – unless there is an objection filed.  There is a 10-year CLP on T1 debts which can be re-started and extended by the CRA.


Corporate (T2)

The CLP starts on the 91st day after a notice of assessment or reassessment is sent unless a NOA or appeal has been filed.  The 10-year CLP applies, however the CLP can be restarted and extended.


Large Corporations (as defined by the Income Tax Act)

The CLP starts on the 91st day after a NOA or reassessment is sent.   The 10-year CLP applies, however, the CLP can be restarted and extended.

This type of tax debt is subject to a 90-day collection restriction for the period after a notice of assessment or reassessment is sent, however, the CRA can act to collect 50% of the amount owing by a large corporation as soon as a notice of assessment or reassessment is sent.  The CRA can start collection action on the 91st day for the remaining 50% of the amounts owed by a large corporation, unless a notice of objection or appeal is filed.


Payroll (T4) Deductions

The CLP starts the day after the Notice of Assessment is sent.  There is a 6-year collections limitation period, however this CLP can be restarted and extended at any time.

NOTE: There is no collections restriction on Trust funds, so the CRA can begin collections actions the day after a Notice of Assessment has been sent.

NOTE: If a Notice of Objection or an appeal has been filed, the CRA can continue to collect the debt(s)



The Collections Limitation Period starts the day after the Notice of Assessment is sent and while the 10-year CLP applies, it can be re-started and extended at any time.

NOTE: Additionally, since GST/HST are also Trust Funds (funds held in trust for the Crown), there is no collection restriction once the Notice of Assessment has been sent.

NOTE: If a Notice of Objection or appeal is filed, the CRA can continue to collect the debt(s).


Collection Restriction Period

For tax debts subject to collection restrictions, the CRA cannot start collection action:

  • during the 90 days after a notice of assessment or reassessment is sent
  • during the time that you dispute your debt by filing a notice of objection or appeal

However, if the CRA determines that it might not be able to collect a tax debt because of collection restrictions, it can apply to the Federal Court (Canada) for a jeopardy order.  If granted, this order will let the CRA take collection action immediately.


Restart of the collections limitation period

The limitation period is restarted when either you or the CRA takes certain actions. Tax debts subject to the 6-year limitation period are restarted for another 6 years and tax debts subject to the 10-year limitation are restarted for another 10 years.

The following are examples of actions that will restart the collections limitation period. This is not a complete list.


Actions you initiate

The collections limitation period will restart when you:

  • Make a voluntary payment
  • Write a letter to the CRA proposing a payment arrangement
  • Offer to provide security instead of paying the amount owed
  • Make a written request for a reassessment of an amount assessed
  • File a notice of objection with the CRA
  • File an appeal with the Tax Court of Canada
  • Ask the CRA if you can make pre-authorized debt payments


Actions the CRA initiates

The CRA takes various actions to collect tax debts when taxpayers don’t make voluntary payments.

The collections limitation period will restart when the CRA:

  • Issues a garnishment or statutory set-off to collect an outstanding tax debt when you don’t make voluntary payments
  • Applies a refundable credit to your tax debt and notifies you by sending a letter or Statement Of Account
  • Issues a NOA or reassessment against a third party for amounts you owe
  • Certifies your tax debt in the Federal Court of Canada
  • Initiates seizure and sale action to collect your outstanding tax debt


Extension of the collections limitation period

The events listed below can extend the collections limitation period. When this happens, the clock stops running on the date that an event begins and it will not run during the event.

This has the effect of stalling the collections limitation period.

When the event is completed, the collections limitation period resumes where it left off.

Other events can then restart the limitation period.  It will end when the 6‑year or 10-year limit has been reached, even if it took more years than that to reach that limit if you include the stalled time.

The following events can extend the collections limitation period:

  • You file an assignment (bankruptcy or proposal) under the BIA, CCAA or FDMA.
  • The CRA accepts security instead of payment of a tax debt.
  • You become a non-resident of Canada after the CRA issues a NOA or reassessment.
  • The CRA postpones collection action without accepting security for an objected or appealed GST/HST debt. This applies only to GST/HST tax debts assessed under the Excise Tax Act.
  • You file a Notice of Objection with the CRA. This will extend the limitation period only for tax debts subject to collection restrictions.
  • You file an appeal with the Tax Court of Canada. This will extend the limitation period only for tax debts subject to collection restrictions.


NOTE: Filing a Notice of Objection with the CRA or an appeal with the Tax Court of Canada will restart the collections limitation period for all types of tax debts because both of these actions are considered acknowledgments of debt.

Similarly, if your tax debt is subject to collection restrictions, filing an objection or appeal will extend the collections limitation period.


End of the collections limitation period

Once the period ends, the CRA cannot take any further action to collect the debt, however, the tax debt still exists and you can make voluntary payments.  Voluntary payments you make after the limitation period ends will not restart it.

SEO Spam, inTAXicating, and Why Businesses Fail

Anyone else get a lot of SEO Spam?

SEO, in case you were not aware is the acronym for Search Engine Optimization, and is a marketing technique which focuses on growing the visibility of your web-site through non-paid search engine results.

To get a higher ranking website, you need a combination of good content and your site has to hit the right keywords.  Doing this will drive traffic to the website, and all of this helps the search engines know that your site needs to be shown to people searching for whatever you have written about.

It stands to reason then, that just because you created a web-site (or blog) it doesn’t mean that anyone will see it or read it.  The site has to be “indexed”, meaning that it needs to show up in search engines, and it gets indexed by having people show up and visit the site.

The more visitors, the higher the ranking.

What does SEO spam have to do with businesses failing?  Directly, a lot, yet indirectly, a lot as well.

In and amongst the spam I get at http://www.intaxicating.ca, I seem to get a LOT of pitches from SEO companies who promise to help me get your website on the “first page of Google”.

Now, I know that a lot of these inquiries are spam because they are fraudulent – trying to steal identities and money – however there are some real companies who reach out to help me improve my site’s ranking.

If you are going to take the time to make a pitch to company, should you not check before you reach out to ensure that you are offering a service which they actually need?

Some of the blog posts contained on the inTAXicating blog already come up on the first page of Google.  In fact, several inTAXicating posts come up before the Canada Revenue Agency when they are being searched.

Forget the offer to be on the 1st page of Google searches.  When you’re number 1 already, why even make the offer of service.

If you cannot see that, what else are you going to miss which is a lot less obvious?

Business fail because they do not take the time to check their prospective client(s) out and they end up making a pitch which shows there is no attention to detail being paid.

In the meantime, when you have a tax issue, and you need the best, contact inTAXicating.  We rank higher than the CRA on CRA tax matters for a reason.



CRA Charge 4 “Tax Protestors” in Quebec with Tax Evasion

The Canada Revenue Agency (CRA) have charged a quartet of “tax protesters” in Québec with tax fraud, alleging that the 4 operated a scheme which helped over 50 participants evade more than $1 million in federal income tax.

Allegations, not yet proven in court, claim that they advised 50 taxpayers to claim losses totalling more than $19 million in losses, or close to $1.08 million in federal income tax.

Pierre Cardin and Sylvain Quirion of Montreal, Jean-Marc Paquin from Laval, and Contrecoeur resident Guylaine Tremblay were arrested and released with a promise to appear, and court-imposed conditions, the CRA reported.

The CRA used this opportunity to reiterate its warning against getting involved with tax protestors, noting that Canadian courts have consistently rejected these schemes.

“For those involved in tax protester schemes, the CRA will reassess income tax, calculate interest and impose penalties,” the announcement says. “In addition, upon a conviction for tax evasion, the court may impose a fine between 50% and 200% of the tax evaded and a jail term of up to five years.”

Earlier this year, the CRA issued an alert about tax schemes claiming that, “natural people” are not subject to tax laws, because it’s not true.

“Individuals who promote such views are “tax protesters” who not only fail to report their own earnings, but they also try to convince others to engage in these illegal activities,” the CRA said in the alert.

The CRA has always kept an eye on these sorts of schemes and regularly uses the opportunity to promote situations where charges are laid, or where the court charges fraudsters in order to remind Canadians to steer clear of this type of tax evasion.

Recently, the CRA reported that, between 2006 and 2017, 75 promoters had been convicted in connection with these kinds of schemes, resulting in $7.15 million in fines and a total of 936 months of jail time.

If someone is charging you money to teach you how to pay less tax, you might want to steer clear.

If, however, you have taken part in a scam, or scheme, or if you believe that you are a “natural person” and that taxation does not apply to you, please send me an email to info@intaxicating, so we can discuss the very significant consequences which you can face.

I won’t judge you.  I’ll listen, and I’ll explain and answer questions.




Tax Shelter Debt with the CRA? Come TONIGHT to a Meeting in Toronto

Have you participated in a Canadian Tax Shelter?

Do you owe the CRA money?

Have the promoters of the shelter taken your money and run away?

If any of these situations sound like a dilemma you are in, or going to be in, then you have a bit of time to do something about it.

The Tax Shelters they will be discussing tonight are; COIP, RLG, MLF and PGI.

If you have participated in any other tax shelter, such as GLGI, and you wish to speak with me regarding your options, please understand that the event will focus on the above 4, however, I will have time set aside after to speak with participants regarding them.


Tonight, November 21st, 2017 is your last chance this year to come and meet with tax shelter and CRA experts on the subject of their Class Defence.

Profitable Giving Canada, the leading Canadian Tax Shelter Solution provider, are especially pleased to have Mr Shy Kurtz,  LLB, BCL, the Chairman of their Legal Affairs Committee as special guest to answer questions and give an update on their Class Defence.

Don’t miss out on this important opportunity to find out how to deal with the CRA reassessments and collections.   It’s your last opportunity for quite some time to speak directly to the experts.

If you have not yet joined their Class Defence,  it is even more critical to attend.  They want to hear from you and you need our help, trust me! 
Event details:

Tuesday, November 21, 2017
7:00 PM-9:00 PM
Hampton Inn & Suites,
Register Now
If you simply cannot attend one of their 2017 final seminars,  they would be pleased to offer you a  private telephone consultation at your convenience.  Or just call them at 519 -964 – 2780

The seminar will be hosted by Mr. Jaye Torley, the President of Profitable Giving Canada.

I will be there too to answer questions on the CRA’s Collections process.

IF you wish to speak to PGC, here is their contact info:

7 Ways the Tax Man is Watching You: MoneySense.ca

When I saw this headline in Money Sense.ca I immediately felt upset that this article was going to be a bunch of made-up, fear-mongering, scare tactics along the lines of something that would come from an advertising campaign from a certain tax law / brokerage firm.

They popularized the calling of the CRA the “tax man” and since we all know the CRA hates that, its worth noting that it a confrontational relationship with the CRA is what they are all about.

Some people need that.

Most don’t.

Then, upon reading the list, I noticed that each and every one of the 7 items has a quote from… Dioguardi, and once the shock and surprise wore off, I shook my head and wanted to set the record straight, as far as I see it.

Not really...
The CRA is watching you!

The link to the original article is here;

So let’s look at these items in a bit more depth;

1. Social media. Sure. If you make it public, and you have a unique name, the CRA can see what you’re posting. It doesn’t mean that if you have $40K in reported income and buy a $100K boat that they are going to assess you. If you are in collections and the CRA’s collections officers are trying to get you to pay, and all of a sudden a boat shows up on their radar, they will do their research and determine who owns it, how it was purchased and if it belongs to someone who owes the CRA taxes, then you have better have a good explanation as to why you didn’t disclose it.

2. Kijiji, eBay, etc. Yes, if you are selling items online as a way to earn an income it is income that you should declare and pay taxes on. The CRA have in the past requested and received information from eBay related to their top sellers. If, however, you are doing this as a business, it would have made sense to have engaged an accountant or tax professional to ensure that you are not only reporting correctly, but that you are claiming all eligible deductions and expenses – like a home office – to offset the income earned. A business is a business.

3. Credit card slips – yes, however only if it’s through an audit and the auditor has requested it directly from you. I suppose if you were under criminal investigation, or were in collections for a long time, the advanced collection techniques might include requesting this information, but the collections staff are not able to do anything with it. Auditors can assess with it. Collections cannot. Very misleading point here!

4. Bank accounts and investments – All financial institutions are required to provide year-end tax slips to taxpayers indicating their position during the year and in each and every case, a copy is sent to the CRA. They already have this information. They’re not watching anyone. The slips the bank sends is matched to the slips the taxpayer files. No slip, then the CRA asks for it (maybe you lost or forgot it) and then if it’s not accounted for, the CRA will raise an assessment.

If a taxpayer is in collections and the CRA wanted to know information about a bank or investment they have the ability to use a Request for Information, to ask for information and a Requirement for Information to ensure they get the information. Both processes are complicated and the CRA must prove that they were denied the information or that they need it urgently in order to raise an assessment.

5. This section is a bit vague and underwhelming. First, the CRA checks the sales records much faster than they did years ago – but they take that information then send out a questionnaire to the taxpayer to complete which is the supporting document they use to assess. They see you sold, but you let them know if there is cause for digging deeper.

On the rent side,, what catches the most number of people is when a renter pays rent in cash and the landlord and the landlord does not provide receipts and neither reports in… until there is an issue, and the renter declares rent paid. The CRA checks the landlord to see if they declared the rental income and when they have not… Assessment. The CRA is, again, not watching people in this case. They come across these assessments because of breakdowns in rental agreements.

6. Income and pensions. This list should have stopped at 5. This is not a case where CRA watches anyone. It’s about reporting and discrepancies.

7. Mystery diners – I’m not even going to comment on this than to say that it’s so over the top it’s unbelievable.

I will add, that while working at the CRA, I did attend restaurants as a representative of the Crown, however I disclosed my reason for being there and it was only in situations where restaurant owners had payroll debts over $300,000, and suddenly reduced their payroll from 15 full-time employees to 2 full-time employees. I just needed to check and see if they really did cut staff, or if they just started paying the other 13 cash under the table, to avoid having to deduct and remit the CPP, EI and tax. In each and every case, upon entering the restaurant, I would count the number of employees – when I saw more than 10, I would take the owner aside, explain this was not legal, then request a payroll audit and be done, until the audit assessment came into collections.

So to conclude, the most accurate part of this article is, “always give full and complete disclosure”.

The “tax man” is not watching you, unless you are in collections, under investigation, or trying to “game” the system.

If you have questions, concerns or comments, and want the truth about your situation, send us an email to info@intaxicating.,ca and we can have that discussion.