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B.C. property firms say $91M tax bill will jeopardize construction

Earlier this month, Vancouver-based Adex Securities Ltd., One West Holdings Ltd. and an affiliated numbered B.C. company asked Federal Court to halt tax assessments from 2007–2013 after a 12-year CRA audit.
The audit began in 2013, probing interest routed to related corporations in Luxembourg amid potential tax avoidance and 'treaty abuse', though the companies say payments were not for avoidance.
Lawyers say the application alleges the CRA acted improperly to maximize recoveries near fiscal-year-end to 'improve performance metrics' amid federal job cuts, while Justin Kutyan, lawyer with KPMG Law in Toronto, said only anticipated future projects may be affected.
The companies say they will 'suffer irreparable harm' if forced to pay the $91 million tax debt plus interest, and court records show the federal government has not filed a response or scheduled a hearing.
Given the Alta Energy Luxembourg ruling and CRA officials' acknowledgment of 'evolution of the law', the case invokes the Supreme Court's 2021 decision on treaty interpretation.

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B.C. billionaire's property firms argue $91M tax bill will jeopardize future projects

B.C. property companies controlled by prominent developer Terry Hui are taking the federal government to court, claiming a tax bill of more than $91 million will jeopardize future construction projects if they're made to pay up after a 12-year audit by the Canada Revenue Agency.

3 months ago·Canada

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