Canada: Maddin: Failure To Inquire Leaves Director Liable

In Maddin v. The Queen (2014 TCC 277), the taxpayer was a director of a corporation in the marble and granite industry (the “Corporation”) which failed to remit nearly $300,000 of source deductions related to salaries, wages and other remuneration paid to employees. The sole issue before the Tax Court was whether the taxpayer could make out a due diligence defence under subsection 227.1(3) of the Income Tax Act (Canada).

For earlier blog posts on […]

By |October 31st, 2014|

United States: Illinois Department Of Revenue Releases Rulings Addressing

The Illinois Department of Revenue recently has released several private letter rulings (PLRs) and general information letters (GILs) which provide taxpayers with guidance on a variety of corporate income tax issues.1 In the area of apportionment, the Department’s rulings address the sourcing of transitory tangible personal property and software, as well as alternative apportionment. Other rulings cover the use of single combined returns when federal short-period returns are required, the state’s conformity with Internal […]

By |October 31st, 2014|

United States: The IRS May Require Taxpayers to File Formal Refund Claims During an Audit

The Internal Revenue Service (IRS) has drafted new rules relating to the filing of informal refund claims during an examination.  An informal refund claim is a request for a refund by the taxpayer either in a written form, but not using a standard form (i.e., Forms 843 or 1120X), or by some other means as long as the required claim elements are identified.  Examples of informal claims are a signed Form 870 or Form […]

By |October 30th, 2014|