Joint Committee, "Submission regarding proposed audit powers in Budget 2024 included in the August 2024 Draft Legislation", 11 September 2024 Joint Committee Submission

Summary Under
Tax Topics - Income Tax Act - Section 231.9 - Subsection 231.9(6)

Inappropriate scope of s. 231.9 rule (pp. 7-10)

  • Where the taxpayer refuses to provide information on the basis of solicitor-client privilege and...

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Summary Under
Tax Topics - Income Tax Act - Section 231.7 - Subsection 231.7(6)

Potentially disproportionate, and therefore penal nature (contrary to s. 11 of the Charter) of the s. 231.7(6) penalty (pp. 11-13)

  • A penalty that...

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Summary Under
Tax Topics - Income Tax Act - Section 231.8 - Subsection 231.8(1)

Inappropriate scope of tolling (pp. 14-17)

The revised version of s. 231.8 would generally expand the circumstances in which the running of the...

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Summary Under
Tax Topics - Income Tax Act - Section 231.41

Procedural protections under the parallel IRC rule (pp. 5-6)

  • Although the IRS has the power to summon various persons including taxpayers,...

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