Tag: Audit

Examination and verification carried out by an outside agency (such as an accountancy firm or the tax authorities) of a taxpayer’s books and accountants and/or the general accuracy of returns and declarations, either as a routine operation, or where evasion is suspected.

Canada vs Sifto Canada Corp, March 2017, Tax Court, Case No TCC 37

Canada vs Sifto Canada Corp, March 2017, Tax Court, Case No TCC 37

The issue before the court was whether the Canadian revenue service had the ability to issue the second reassessments given the Canadian and US competent authorities subsequently agreed on a MAP settlement. The Tax Court found that a settlement agreed to via the competent authority precluded a subsequent tax-reassessment that attempted to further increase the taxpayer’s income. Canada vs Sifto Canada Corp, 2017 Case No TCC 37 ... Continue to full case