Sentences with phrase «revenue agency decision»

successful challenge of a Canada Revenue Agency decision to deny interest relief for a large U.S. commercial bank;

Not exact matches

Moreover, in this line of cases, there already had been a decision that adopts a two - part test for bona fide tax - exempt nonprofit credit counseling agencies, requiring such agencies to: (1) be recognized by the IRS as being exempt from federal income taxation under section 501 (c)(3) of the Internal Revenue Code; and (2) actually operate as a bona fide nonprofit organization.

The Canada Revenue Agency's decision to audit the eBay sellers follows a series of Federal Court decisions confirming the tax authority's ability to force eBay's Canadian companies to disclose the names and other contact information of the Canadian PowerSellers.

The decisions clarified that legal professionals can not be compelled to disclose their clients» identities, communications or any other privileged information with respect to tax audit and / or collection powers of the Canadian Revenue Agency («CRA»).

On June 3, 2016, the Supreme Court of Canada, in two related decisions, strengthened the legal protection of solicitor - client privilege in relation to Canada Revenue Agency's (CRA) audit and tax collection powers when it decided the federal Income Tax Act's «requirement» scheme is unconstitutional insofar as it applies to lawyers and notaries, and the lawyers» accounting records exception in the Act's definition of «solicitor - client privilege» is completely unconstitutional.

Our senior lawyer has over 20 years experience with government decisions including Canada Revenue Agency, Canada Border Services Agency, Citizenship and Immigration Canada, the RCMP, Correctional Service of Canada, the Department of Fisheries and Oceans Canada, and the Courts Administration Service.

In September of last year, I blogged about a decision of the Federal Court of Canada that ordered eBay to hand over to the Canada Revenue Agency information about Canadian «power sellers».

A California federal judge has granted the Internal Revenue Service's motion to dismiss a $ 7 billion lawsuit brought by Facebook Inc. that alleged the IRS unjustly denied the social media company's right to appeal the agency's decision to adjust its taxes after an audit of its returns.

Speaking as part of a recent panel discussion at the University of Toronto entitled «Copthorne Holdings Ltd. and the Future of the GAAR,» Phil Jolie, director general of the Canada Revenue Agency, said that while he found the decision to be a good one, it won't change things at the CRA.

Proprietary, innovative tools designed to share data with agency partners enable agencies to make better, faster decisions — thus driving more revenue.

• Audited case records for Title IV - E Eligibility and Federal Funding Stream conversion generating unclaimed federal revenues totaling $ 24,000,000 in two years, directly affecting descriptive projective results appropriate for agency decision - making.