CIFPs: Tax & Budget 2012 Update
CIFPs: Tax & Budget 2012 Update
CIFPs: Tax & Budget 2012 Update
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T1135 – Foreign Income Verification Statement<br />
CRA changed its “one chance” administrative policy and assesses<br />
penalties even for first-time failure<br />
2009 & 2010 T1135 cases:<br />
• Leclerc v The Queen (2010 TCC 99)<br />
• Sandler v. AG (2010 FC 459)<br />
• Seabrook et al v The Queen (2009 TCC 532)<br />
2011 Asper cases – 7 companies:<br />
• T1135s not filed from 2000 to 2005, but all income reported<br />
• Penalties (over $75,000) upheld under judicial review<br />
• FCA dismissed appeal<br />
“although the Minister's decision was unreasonable, no practical end<br />
would be served by returning the matter to him for redetermination”
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