Oct 3, 2019
Tax authorities have become increasingly aggressive in auditing taxpayers and challenging tax planning arrangements, even structures that many would consider “plain vanilla.” The targets of these audits could be any taxpayer: large public corporations, SMEs, family businesses, family offices and individuals. The tax authorities are testing the limits of their audit powers by demanding interviews of management employees and making broad requests for information and documentation. Further, there has been a significant increase in audit activity by Revenue Québec, which is bringing more and more cases to court. This means that taxpayers operating in Québec face the reality of having to deal with two tax authorities, sometimes acting independently and sometimes adopting contradictory positions. This put taxpayers to the task of having to defend their structures.
This seminar focused on recent audit activity and initiatives at the federal and Québec levels, including cases involving arguments of sham and ineffective transactions, challenges to loss consolidation planning and the increasing application by the tax authorities of gross negligence penalties and assessment of statute-barred years.