For the CRA to successfully win a joint-liability assessment, four criteria must be met: there must have been a transfer of property, the transferor and the transferee must not have been dealing at arm’s length, there must not have been adequate consideration paid by the transferee to the transferor and, finally, the transferor must have had an outstanding tax liability at the time of the transfer.
From 1995 to 1997, the couple received salaries from their corporation, but in 1998, the corporation began paying the couple dividends as well, and, other than in 2004, each spouse received dividends from the corporation annually until 2013. From 1997 to 2012, the couple also earned employment income and/or business income from the corporation.
In other words, the couple asserts the corporation paid for their services through a combination of salary and/or dividends and that, while the mix of those components of remuneration received varied from year to year, in all cases the total amounts paid to them by the corporation was consideration for the services they provided. Any change in the mix of payments was a function of tax advice they had received from their accountant and was made “for tax planning purposes.
The Tax Court judge therefore concluded the dividends could not be said to be consideration for services performed, and thus the couple was personally liable for the tax debts of the corporation, having received dividends totalling more than the $86,848 tax debt.
My exgf works for the CRA. She’s certified CRAZY (like on medication) and randomly sends me information she has pulled out of my records.... be scared. We broke up 12 years ago.
The CRA can eat 💩. They have no problem going after the little guys/gals, but let the wealthy and corporations launder and move money offshore without blinking an eye.
Panama Bill and the gang aint worried about the CRA
It is the patriotic duty of Canadians to deny this government of any funds we can. We earn our money. The lazy kid on the couch collecting CERB didn't.
Bloody hell. I don't give a flying ferret if 'Joe Shmo $60K' hides a couple of assets when nearly $400 billion in corporate tax evasion is going off-shore in tax havens. And the Liberals and Conservatives vote to do nothing about it, or close the stockoptions loophole.
What assets
Unless youre wealthy enough to be on this list amiright? You know, the good folks that National Post et al and our govts actually work for while they continue the upward wealth transfer.