Shelley J. Kamin, Barrister & Solicitor focuses on tax law planning and disputes, with additional expertise in business law, estate planning and wills.
Effective Strategy and Results in Business and Tax Law: Recent Examples
Transfer Pricing
An Ontario company with annual sales of $30 million underwent a transfer pricing audit concerning pricing practices with its Swiss parent company. The CRA auditors agreed no adjustments or reassessments were necessary.
Financing of Retail Operation
Legal assistance to 13 individuals, trusts and corporations investing $1.8 million in financing for an Ottawa business.
Purchase of a Business
Legal assistance to a corporation and individual in their $1 million buyout of an Ottawa business.
Reorganization with Family Trusts
Two family trusts were reassessed an additional $10.6 million resulting from a succession-planning reorganization. The Department of Justice agreed early in the Tax Court proceedings to completely vacate the reassessments.
Directors’ Liability
Two former directors of a corporation were assessed a total of $1.5 million for source deductions arrears and GST/HST. The CRA Appeals Division agreed to completely vacate the assessments.
Employees or Independent Contractors
Workers engaged by a local company as independent contractors were reassessed as employees. The Tax Court agreed the workers were independent contractors.
Debt Forgiveness
Individual and corporation were reassessed an additional $5.4 million from a forgiveness of debt owed to another corporation. The CRA Appeals Division agreed to completely vacate the reassessments.
