Audit and Assessment Procedure


James v. Canada, 2001 DTC 5075 (FCA)

The matter was remitted for a new trial on the basis of a finding (at p. 5082) that on some occasions the trial judge had "acted in a manner that could reasonably lead an objective observer to conclude that he had taken on the role of counsel for the Crown" (pp. 5082-83). The Court stated (at p. 5082) that "the general rule is that a judge may ask a witness questions of clarification and amplification, but should not intervene in the questioning of a witness to such an extent as to give the impression of taking on the role of counsel".

Locations of other summaries Wordcount
Tax Topics - General Concepts - Evidence 54
Tax Topics - Income Tax Act - Section 165 - Subsection 165(3) vacating not a remedy for lack of due dispatch 86
Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) no s. 56(2) inclusion to taxpayer if recipient of the transferred property had earned it rather than the taxpayer 332

Administrative Policy

20 June 2023 STEP Roundtable Q. 13, 2023-0966611C6 - Trust Online Verification

launch of My Trust Account

My Trust Account, which was launched on February 6, 2023, gives those with the appropriate authorization the ability to view and update some account information including address, direct deposit, authorizing a representative, and submitting documents on behalf of the trust.

26 November 2020 STEP Roundtable Q. 16, 2020-0839921C6 - Offshore Tax Informant Update

OTIP stats at end of 2019

When asked for updates on the offshore tax informant program, CRA stated:

Since the OTIP launch, there has been sustained interest in the program by potential informants. As of December 31, 2019, the OTIP has received nearly 5,500 calls of which of over 1,600 have been from potential informants, received over 750 written submissions and has entered into nearly 50 contracts with informants.

In addition to what was provided previously, over 150 audits of taxpayers have been completed, nearly $60 million has been assessed of which approximately $20 million has been collected and over 300 audits of taxpayers are in progress.

COVID-19: Information for Canada Revenue Agency employees: 30 March 2020: Work restrictions for critical and non-critical services

Previous COVID-19 work arrangement

On March 15, 2020 we announced that because of the COVID-19 pandemic, only employees performing critical services would be required to continue to work until April 5, 2020.

Extension of arrangement to May 1, 2020 for Category 1

Effective today, March 30, 2020 and until May 1, 2020, employees who perform critical services will be asked to continue working as has been the case since March 15, 2020, but we are changing some of the work restrictions for other employees. To make sure you know what is expected , we have categorized your work into 3 groups:

  • Category 1: You perform a critical service

You are expected to continue to work, preferably from home, to deliver critical services for Canadians as defined in the National COVID-19 Business Continuity Plan. If working from home is not possible, we ask that you continue to report to the office. We are continuing to implement measures to ensure the health and safety of all employees who support critical services in the workplace, including more stringent disinfection protocols and arrangements to enable physical distancing.

  • Category 2: Your work, while important, has not been identified as a critical service, but you are equipped to work from home

You can work from home, but only if you do not create work for others who are performing critical services as defined in the National COVID-19 Business Continuity Plan.

  • Category 3: You do not perform a critical service identified in Category 1 and you are not equipped to work from home, OR you are not able to work because you have to care for children during school closures, for individuals who are sick, or for other dependents

You should stay home and enter your time away ... .. For those who are not equipped to work from home, you may be contacted by your manager to come into the office to pick up equipment ... .

91 C.R. - Q.58

The statement in IC 77-9R concerning the disclosure in a T1 return of an interest in a controlled foreign affiliate or the beneficial interest in a non-resident discretionary trust is intended as a suggestion rather than a requirement.

91 C.R. - Q.57

District Office audit screeners can obtain computer-generated listings of persons who have claimed a capital gains deductions and they can select audits from these lists.

91 C.R. - Q.56

No formal request for a copy of the T20 audit or T401 appeals report is required.

91 C.R. - Q.55

Head Office's input is provided upon request; it generally does not have any input into the preparation or content of a position paper or audit report.