 Copyright
Disclaimer  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
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
Introduction 21.1 Tax Avoidance / Evasion 21.1.1 Tax Avoidance 21.1.2 Tax Evasion 21.1.3 General Anti-Avoidance Rule 21.1.3.1 Reporting Obligations for Aggressive Tax Planning 21.2 No Reasonable Expectation of Profit 21.2.1 Personal or Living Expenses 21.2.2 The Moldowan Test 21.2.3 The Stewart and Walls Cases 21.2.4 What Is Reasonable Expectation of Profit? 21.3 Giving Tax Advice on Investments 21.3.1 Hodgkinson v. Sims 21.3.2 Tax Shelters 21.3.3 Penalties 21.3.4 Cases of Interest 21.4 Transfer Pricing 21.5 Reporting 21.5.1 Tax Shelter Reporting 21.5.2 Construction Contractors — Contract Payment Reporting System 21.6 The Offshore Sector — Reporting Rules 21.6.1 Transfer Pricing Filing Requirements — Information Returns (Form T106) 21.6.1.1 Reporting Person's Information Return Practice Aids Practice Aid 21.1 T5001, Applying for a Tax Shelter Identification Number and an Undertaking to Keep Books and Records Chapter 22 Taxation of Non-Residents
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