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.
Legal assistance to 13 individuals, trusts and corporations investing $1.8 million in financing for an Ottawa business.
Legal assistance to a corporation and individual in their $1 million buyout of an Ottawa business.
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.
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.
Workers engaged by a local company as independent contractors were reassessed as employees. The Tax Court agreed the workers were independent contractors.
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.