Navigate the 2025 expansion of CRA audit powers and enforcement tools. Master strategies to mitigate compliance risks and protect taxpayer interests in this new regime.
Join expert practitioners in the course CRA Information Collection: 2025 Update as they explore the seismic shifts occurring in Canadian tax administration. With the federal government introducing expanded audit and information collection powers, the traditional balance between voluntary cooperation and compulsory enforcement is rapidly changing. This course features in-depth insights from legal experts Marie France Dompierre and Jacob Yau, who dissect the legislative background of the 2024 and 2025 reforms and their profound implications for lawyers, accountants, corporations, and individual taxpayers.
The curriculum provides a comprehensive breakdown of the Canada Revenue Agency's new toolbox, moving beyond historical audit functions to examine aggressive new enforcement mechanisms. Participants will gain a detailed understanding of the power to compel interviews under oath, the introduction of the Notice of Non-Compliance, and the new rules regarding the tolling of limitation periods. The discussion addresses the significant financial penalties associated with these measures, as well as the downstream risks regarding solicitor-client privilege and constitutional Charter rights.
Beyond the legislation, this course focuses on practical application. You will learn how to navigate an increasingly adversarial audit environment, manage client exposure, and implement robust documentation strategies. Key learning outcomes include:
This course is essential for tax practitioners and legal professionals who need to prepare for a more rigorous enforcement landscape. By understanding these pivotal changes, you will be better equipped to protect your clients from substantial compliance costs and legal exposure.
Partner at Davies Ward Phillips & Vineberg LLP
Jacob combines technical tax expertise and strategic thinking to help his clients navigate complex tax disputes. He has argued before the Tax Court of Canada and the Federal Court of Appeal on matters ranging from income tax, excise tax, and the general anti-avoidance rule (GAAR) and he has successfully resolved numerous cases before trial. He has also argued before the Federal Court of Canada on judicial review applications and the Ontario Superior Court (Commercial List) on orders for rectification and commercial disputes. Clients look to Jacob for guidance on voluntary disclosures, tax compliance, audits, objections and appeals. He advises both domestic and international clients on corporate tax, tax planning, M&A, business structuring and reorganizations. In the Chambers Canada guide, one client referred to him as “knowledgeable, professional … and dedicated to the client and task. Obviously, and lucky for us, he is a man who takes no prisoners.” Jacob is an active publisher and speaker and is an editor of Federated Press’ International Tax Planning.
Partner at Davies Ward Phillips & Vineberg LLP
Marie-France works with Canadian and international clients to avoid, manage and resolve domestic and international tax disputes with provincial and federal tax authorities. Corporations and high-net-worth individuals – including athletes and entertainers – turn to her for guidance at every stage of the tax dispute process, from audit to appeal to trial. A skilled and strategic litigator, she regularly represents clients before all levels of Court including the Tax Court of Canada, the Federal Court, the Federal Court of Appeal, the Supreme Court of Canada and the Québec Court of Justice. She has advised on a wide range of complex tax issues, namely cross-border and international taxation, taxation of high-net-worth individuals, business and real estate taxation, including indirect taxes, as well as Scientific Research and Experimental Development (SRED) and other tax credits. Before joining Davies, Marie-France practised at a full-service regional law firm and a leading law firm affiliated with an international professional services firm. She previously served as counsel with the Department of Justice, representing the Canada Revenue Agency in tax appeals, and as a Crown prosecutor focusing on the proceeds of crime and tax fraud. Marie-France articled as a judicial law clerk at the Tax Court of Canada.
