Non-Arm’s Length Transfer Assessments
Section 160 of the Income Tax Act and Section 325 of the Excise Tax Act pave the way for the Canada Revenue Agency to assess third parties for the tax debt owed by others.
Quite often the Canada Revenue Agency assumes incorrect facts regarding the alleged transfers and the relationship between transferor and transferee. It is not unusual for the CRA to later admit, upon reviewing submissions made on your behalf, that the conditions precedent for issuing such memorandum assessments were not satisfied and vacate or cancel the assessments altogether.
At Mather Tax Law, we have considerable experience in helping clients successfully defeat non-arm’s length transfer assessment issued pursuant to both section 160 of the Income Tax Act and Section 325 of the Excise Tax Act.
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