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CPAstore - Tax Risk Management Guide (TRMG)

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What's New

Introduction to the Tax Risk Management Guide

About the Authors

Chapter 1 Deadlines and Penalties

Chapter 2 Tax Risk Questionnaire (discontinued)

Chapter 3 Tax Service Responsibility

Chapter 4 Links to Important Concepts

Chapter 5 Dealing with the CRA

Chapter 6 Appeals to Tax Court

Chapter 7 Researching Tax Law

Chapter 8 Taxpayer Relief Provisions, Collections and Third-Party Liability

Introduction: Taxpayer Relief Provisions

8.1 The CRA's Administration

8.1.1 Application for Relief in Respect of Interest and Penalties

8.1.2 Guidelines

8.1.2.1 CRA's guidelines

8.1.2.2 Other factors

8.1.2.3 Considerations

8.1.2.4 Refund interest

8.1.2.5 Relevant taxation years

8.1.2.6 Examples of relief

8.1.2.7 Exercise of discretion

8.1.3 Protective Requests

8.1.4 Miscellaneous

8.2 CRA Collections

8.2.1 Payment Obligation

8.2.2 Role of Collections

8.2.3 The Collections Process

8.2.4 Payment of Disputed Taxes

8.2.4.1 Payment plan

8.2.4.2 Proactive approach

8.3 Third Party Liability

8.3.1 Director's Liability

8.3.2 Due Diligence

8.3.3 Limitation of Director's Liability

8.3.4 De Facto Director

8.3.5 Liquidator-Director

8.3.6 Payers of Wages

8.3.7 Shareholder's Liability

8.3.8 Non-Arm's Length Transactions

Practice Aids

Practice Aid 8.1 Information Circular 07-1R1 Tax Relief Provisions

Practice Aid 8.2 RC4288 Request for Taxpayer Relief

Practice Aid 8.3 Directors' Liability CRA Information Circular 89-2R3

Practice Aid 8.4 GST Memorandum Series 16.3 Cancellation or Waiver of Penalties and Interest

Practice Aid 8.5 RC376 E Taxpayer Relief Request — Statement of Income and Expenses and Assets and Liabilities for Individuals

Chapter 9 Access to Information Act and Privacy Act

Chapter 10 Advance Tax Rulings and Technical Interpretations

Chapter 11 Tax Return Preparation and CRA Electronic Services

Chapter 12 Deceased Taxpayers

Chapter 13 Remission, Rectification and Rescission Orders

Chapter 14 Purchase and Sale of a Business

Chapter 15 GST/HST Issues (2018)

Chapter 16 Estate Planning

Chapter 17 The Taxation of Trusts

Chapter 18 Taxation in the United States

Chapter 19 Section 85

Chapter 20 Share Attributes

Chapter 21 Other Areas of Risk

Chapter 22 Taxation of Non-Residents


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