Required:- Explain:-

1. The process in place for conflict resolution between a Canadian taxpayer who disagrees with a Notice of Assessment and the Canada Revenue Agency?(4 marks)

2. How CRA levies interest and penalties on Canadian taxpayers (7 marks).

3. The Federal Administrative provisions for filing tax returns(8marks)

PART B6 MARKS)

Required:-For the following independent cases, explain the residency status of the corporations and their tax consequences:-

CASE A:- Jim, James and Jhonny graduated from the engineering program of the University of British Columbia, Canada in 2009 . They maintained their friendship after leaving University. In 2014 they got together and incorporated the Y Company in Buffalo, New York, USA, specializing in providing engineering services to the building industry. By 2021, Y Company had established offices in several countries of the world including Canada. The Board of Directors of Y consisting of 10 members was located in Toronto, Canada, where all the meetings were held( 4 marks).

CASE B: The X Company was incorporated in Montreal Canada in 2008. X was in the business of transporting oil products from Saudia Arabia by tankers across the seas to the United States.

All the shareholders and members of the Board of Directors are residents of the United Kingdom(2marks).