Pooja Mihailovich
Apr 19, 2024
Among the measures introduced in Budget 2024, are some that have tax lawyers concerned, including a “notice of non-compliance” which can be issued against taxpayers who have not responded to earlier Canada Revenue Agency (CRA) requests for information or assistance. If the budget is adopted unchanged, that penalty will be set at $50 per day, up to a maximum of $25,000. In an article for Law360, John Schofield details how the notice would work, explains other proposed changes and solicits the opinions of tax experts, including Osler partner in the Tax group, Pooja Mihailovich, about their potential effects.
“If implemented in its current form… the proposed new penalty creates significant uncertainty for taxpayers, since the final determination of the aggregate tax payable by a taxpayer can take years, and sometimes decades, to finalize,” said Pooja.
She explained that the CRA might take the penalty as an incentive to issue more and more expansive demands — demands that a taxpayer might be unwilling to challenge due to the financial risk.
Read the full article on Law 360’s website