When a corporation fails to remit its payroll withholdings or Goods and Services Tax/Harmonized Sales Tax (GST/HST) to the Canada Revenue Agency (CRA), the company’s directors can be held personally liable for those unpaid amounts in certain circumstances. Stepping down from a directorship does not automatically absolve someone of these tax obligations. In fact, Canadian tax law imposes a “two-year clock” on director liability: the CRA cannot commence an action aga…
Aggressive tax planning by wealthy individuals and complex business structures poses a significant challenge to the integrity of Canada’s tax system. In response, the Canada Revenue Agency (CRA) has bolstered its compliance arsenal, including the creation of specialized audit units. Foremost among these is the High Complexity Audit Tax Services Office (TSO) (also known as HCATSO) – a dedicated office within the CRA focused on the most complex and high-risk tax file…
If you’re a corporate director in Canada, you could face personal liability for certain unpaid tax debts of your company. The Canada Revenue Agency (CRA) can assess directors personally for unremitted GST/HST and payroll source deductions (income tax, CPP, EI) under section 227.1 of the Income Tax Act (Canada) (ITA) and section 323 of the Excise Tax Act (Canada) (ETA). However, there is an important safeguard for responsible directors: the due diligence defence. Th…
Introduction and Objective
The Canada Revenue Agency’s Related Party Initiative (RPI) is a specialized compliance program targeting high-net-worth taxpayers and their interconnected entities. The RPI’s core objective is to identify, risk-assess, and take compliance action on instances of tax non-compliance among the wealthy and their related networks. In practice, this means the CRA examines entire groups of related parties – individuals, corporations, trusts, p…