# Need help with CRA G.S.T. debt I did not know I had!



## Maxpower (Oct 29, 2012)

This is a strange situation and I have been reading for the last week to try and find out how to resolve it but the only info I can find is in tax court judgements which is something I want to avoid if at all possible.

Recently I found out that the CRA is coming after me for a G.S.T. debt owed by a company, a family company, in which I was unknowingly listed as both a director and incorporator even though I never signed the incorporation application or saw the notice of articles (B.C.) or heard any word of director appointments and had nothing to do with the incorporation filing.

When I asked how the company was set up I was told I was a %20 shareholder. If the true incorporator knew the legal meaning of director he never would have listed me due to prior conflicts he had in previous partnerships, he wanted sole control and even though that was the case in reality I am now getting stuck with paying for his mistakes, which I essentially saw coming before I got out of there. I never even knew I was listed as a director since the person that did the incorporation did not inform me he listed me as one nor did I act in any capacity as one, represent myself as one and in no way ever gave my consent to be registered as one.

The company that this is in regards to never filed an annual report with the B.C. registry and must have been dissolved within 1 or 2 years of being incorporated. I left the company after about 6 months because as a shareholder I saw that there was no desire to build a company and instead the goal of the sole de facto director was to suck as much money out of it as possible, I wasn't interested in that at all, so I left after the 1st job. The alleged G.S.T. debt arose around 9 months after I quit. Recently I filed a few years tax returns in order to get a refund due to being in dire straights only for it to be "set-off" against a G.S.T. debt I did not know I had since all of the assessments were directed towards the company I did not know I was a director of and I never received any assessment in my name as an alleged director, therefore, I did not know about the debt. The CRA is now telling me that I have to get the de-facto director to do a limited restoration of the company, which costs about $400, then send in a "Form 10: Notice of Change of Directors" to have my name removed as a director from the notice of articles, which I'm not sure is even possible, especially considering I have been told the company "records" have been lost.

To put it mildly I am suspicious that the above process will just end up being a runaround, if it is even possible to do what they ask, and that if it is possible the CRA will just change the rules in the middle of the process by creating even more ridiculous prerequisites.

I have read through judgements from the tax courts and not knowing you have been listed as a director does apply with the due diligence clause in section 227.1 such as was the case in Cybulski v. M.N.R. and Sheremeta v. M.N.R., because the proper due care of someone who does not know they are a director in regards to G.S.T. remittance is to do nothing, which considering I left the company 9 months prior to the assessed debt definitely applies. 

Does anyone have any advice on the best way to deal with the CRA in this matter now that I have hit a brick wall with the collections agency telling me I have to get the company restored through the registry and have my name removed at a cost of over $500 with no guarantee that that will even work?


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## Maxpower (Oct 29, 2012)

*Maybe getting my name removed as director will work, still unsure*

I phoned the CRA today and again they confirmed that if I am removed from the registry as a director of the company the liability that is currently applied to me for unremitted G.S.T. will no longer exist. They said they have heard of other similar cases. Then I phoned the registry and they said if another director, the real director, files for the limited restoration and files "Form 10: Notice of Change of Directors" explaining I never consented to be a director, never acted as one and never knew I was registered as one that there should be no problem amending the registry to remove my name as director completely. They have also heard of similar cases.

Should I attempt to get this in writing from the CRA or just accept what the first CRA representative and the second confirming representative said? The second representative stated that it was CRA policy not to place liability on a director who was improperly registered and then removed.

Anyone know how trustworthy the word of these representatives is? Should I go on the supposition that they are acting in good faith and telling the truth or should I be mistrustful of everything they say? I have never dealt with the CRA before but I have read some horror stories and what I was told happened to the company I was improperly listed as a director of confirms alot of that to me. The only reason there is a G.S.T. debt owing is because the company was doing the first phase of a building and was told the second phase would start a few wakes later. A few weeks later ended up being approx 5 months from what I'm told and in the interim the CRA continued sending G.S.T. assessments as though the company was still working. The person running the company never disputed the assessments so it was definitely partially his fault what happened next, which was the company account was seized making it impossible for it to do the next phase. That non-existent G.S.T. remittance has mushroomed in size since due to interest. Now the directors are liable for a non-existent G.S.T. remittance, forced to pay for something which sunk the company, plus interest, due to not fighting the assessment when it was received. I guess the lesson there is to put any assessments coming from the CRA on an extremely high priority list.


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## kcowan (Jul 1, 2010)

CRA are telling the truth. The real director just has send them a letter stating that you were never a director. This will remove your liability. But I see that the real director is not trustworthy having listed you in the first place. So he cannot send such a letter stating that you were never a director. I think you will remain as a director and share in any liability that ensues.

I have had similar issues with the CRA even when I had ceased to be a director. Once the CRA got the documentation of that cessation, they left me alone. The process also applies to remittances for income tax of employees, where directors are jointly liable for them.


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## MoneyGal (Apr 24, 2009)

What kcowan said. 

You are factually listed as a director of this company on the company's articles of incorporation. You need to get yourself un-listed as a director, then you will not be liable for the unremitted GST.


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## Robillard (Apr 11, 2009)

Just as a side note, I would mention that it is the CRA's standard practice, where an assessed delinquent tax liability exists, to collect on the outstanding liability by seizing refunds or other amounts that you might otherwise be owed by the government. I worked with a client once who was reassessed for corporate income tax, and the CRA collected on or withheld GST rebates and T4 overpayments to satisfy part of the corporate tax liability.


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## Maxpower (Oct 29, 2012)

kcowan said:


> CRA are telling the truth. The real director just has send them a letter stating that you were never a director. This will remove your liability. But I see that the real director is not trustworthy having listed you in the first place. So he cannot send such a letter stating that you were never a director. I think you will remain as a director and share in any liability that ensues.
> 
> I have had similar issues with the CRA even when I had ceased to be a director. Once the CRA got the documentation of that cessation, they left me alone. The process also applies to remittances for income tax of employees, where directors are jointly liable for them.


 As far as this situation goes the problem wasn't trustworthiness it was negligence. At the time the better position for him would have been to place himself as sole director. A sole director with a very large majority shareholder position would have been in a much better position to control the outcome of the company than he would have been if what he sent in to the registry was actually implemented on the business end. And there was no way he foresaw the current outcome.

Part of the problem is that the place he had the incorporation done, a registry search company, also did not know the procedure and informed him it was necessary to have a president, vice president and secretary which may have been the case in the B.C. Company Act that was in force in 2004 and before but it is not the case in the B.C. Business Corporations Act which is what he should have been following, that may have been one of the underlying reasons more than 1 director was listed at all, due to thinking they were a necessity. From talking to him he has confirmed that he had confounded shareholder with director, not knowing that director had a specific legal meaning, and if he actually knew the legal rights and powers of directors at the time he listed me as a director he never would have done it due to conflicts with prior partners and the fact that listing me as a director could have potentially diluted his power to run the company however he wanted.

The completing party, who would in many cases be a lawyer, also kind of screwed up because he is not supposed to send in the "Notice of articles" or the "Incorporation application", both of which are purely digital forms that are never signed and instead appear to be a digital semi-confirmations of the signed legal documents: the "Incorporation agreement" and the "Articles", unless he has seen all the signatures on the latter legal forms and because of that he did not completely fulfill his responsibilities as the completing party. Also best practices as far as directors goes would be to have a signed confirmation or at least direct verbal confirmation from each director before submitting them to the registry on the "notice of articles". On the other hand it is hard to put much blame on him when it was and probably still is, from what I have read anyway, common practice for less diligent lawyers to just date those legal papers to the incorporation date and get the signatures afterwards with the directors consent generally being nothing more than an afterthought due to the assumption that a directors meeting will be held.

I am not resolving myself of responsibility in all of this because with hindsight I clearly see that I should have inquired more than just asking how the company was set up and accepting the answer that I was %20 shareholder and not doing much more than that. It was naivety at its worst. In having to deal with this I've gotten what I deserved.


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## Maxpower (Oct 29, 2012)

MoneyGal said:


> What kcowan said.
> 
> You are factually listed as a director of this company on the company's articles of incorporation. You need to get yourself un-listed as a director, then you will not be liable for the unremitted GST.


 Thanks for the replies. I am still not sure about how much faith I should put into what the CRA officers say I should do due to hearing alot of horror stories. I am also wondering if the CRA has ulterior motives for insisting the company be reinstated. I have never received an assessment in my own name and instead they are claiming that their collection action against me is derivative to the corporate assessment and I do not really even know if that is allowed, it sounds extremely unusual to me. Especially considering that the very 1st CRA representative I talked to, at the local office, said "Now why did they do that?!" and since then that department will no longer takes my calls at all. The entire situation is bizarre because it has come right out of left field and I have zero documentation regarding it, and now, strangely, the CRA is giving me advice on what to do to remove my alleged personal liability. That alone makes me very suspicious. They are not in the business of helping people remove debts owed to CRA and instead it is the exact opposite, their job is to collect as much of them as they can regardless of liability and stupid family mistakes. Mistakes they readily spend large sums of money to fight in court.

Before I do anything I am obviously going to have to get some documentation from the CRA and talk to a lawyer, the whole thing is way too strange to just do what they suggest without verifying for myself, somehow, that their collection actions is legitimate.


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## MoneyGal (Apr 24, 2009)

You should get independent advice, absolutely. However, the situation you've described is not actually bizarre. Corporate directors can be held personally responsible for the unpaid tax and other debts of the corporation, including HST. Random link from google: http://www.dpclaw.ca/blog/should-you-become-a-director-of-a-new-technology-start-up/

Here's the actual information circular from CRA which provides the legislative authority to hold directors personally responsible for the unpaid tax/other debts of the corporation: http://www.cra-arc.gc.ca/E/pub/tp/ic89-2r2/ic89-2r2-e.pdf

Googling "corporate director responsible for unpaid HST" brings up hundreds of links. Reading these may be a better use of your time than reading tax court judgements.


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## Maxpower (Oct 29, 2012)

MoneyGal said:


> You should get independent advice, absolutely. However, the situation you've described is not actually bizarre. Corporate directors can be held personally responsible for the unpaid tax and other debts of the corporation, including HST. Random link from google: http://www.dpclaw.ca/blog/should-you-become-a-director-of-a-new-technology-start-up/
> 
> Here's the actual information circular from CRA which provides the legislative authority to hold directors personally responsible for the unpaid tax/other debts of the corporation: http://www.cra-arc.gc.ca/E/pub/tp/ic89-2r2/ic89-2r2-e.pdf
> 
> Googling "corporate director responsible for unpaid HST" brings up hundreds of links. Reading these may be a better use of your time than reading tax court judgements.


 In the CRA circular you linked to it states:

21. If a director does not reply within the time set out in 
the proposal letter, the Agency may issue an assessment 
without further notice. 

But what they are telling me is that the notice of assessment directed at the company gives them the ability to enforce collection action against me personally.

They have not directed a notice of assessment at me personally. The assessment against the company would attach to the companies assets but I do not see how a notice of assessment directed at ABC Ltd. can be used as an excuse to proceed with collection action against 1 individual. For one thing it does not give me the ability to file an objection to the assessment as an individual separate from any other directors.

I am starting to wonder if they may be telling me outright lies so I will restore the company therefore restarting all the directorships exactly as they were when the company was dissolved which would allow them to get around the 2 year statute of limitations, which is definitely over by now, so they can assess everyone just like they wish they had of from the start, which is exactly what they probably should have done.

If they had of already assessed me and the objection period was over there is absolutely no way they would be telling me how to remove that liability, so why on earth is the CRA so vociferously trying to show me an out, one that involves restoring a company? To me that is definitely bizarre. If they had a certain legal standing right now they would be telling me there is nothing I can do because the objection period has lapsed. Instead they want me to do the one thing that would allow them to directly assess anyone that was a director when the company was dissolved and coincidentally that is also the only thing, according to them, that will remove my liability. That is an odd coincidence so I am definitely skeptical and I'm certainly not doing anything without some paperwork and an appointment with a lawyer. Up until today they had me convinced enough that I was seriously considering it, but now I it is becoming clear that that is an extremely bad idea without more info from them. Also as I said above my first contact with them seems very strange, especially now that I am wondering if they are attempting to use me to restore a company in order to accomplish their ends.


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## MoneyGal (Apr 24, 2009)

The VERY FIRST sentence of that circular states:

This Circular outlines the consequences which
corporate directors may face, when the corporation, of which
they are a director, fails to deduct, withhold, remit, or pay
certain amounts of money held in trust for the Crown. Under
these circumstances, corporate directors may be held
personally liable pursuant to section 227.1 of the Income Tax
Act (“ITA”), section 323 of the Excise Tax Act (“ETA”),
section 81 of the Air Travellers Security Charge Act
(“ATSCA”), subsection 295(1) of the Excise Act, 2001
(“EA2001”), and similar provisions of the Canada Pension
Plan, and the Employment Insurance Act.

/quote

They don't need to levy a NOA against you personally. You are personally liable for the unpaid corporate debt. This is not the same as a personal liability for unpaid personal taxes. 

Good luck in your search for advice.


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## Maxpower (Oct 29, 2012)

The lawyer I spoke to yesterday informed me that they did have to. The notice of assessment against the corporation is separate. There are even court cases that clearly indicate that a NOA against the corporation is not necessary in order for the CRA to file an NOA against a director. The key words in the first sentence of the above circular are the ones in bold "may be held *personally liable*". From what I have been told it means that they send out a NOA against an individual that is a derivative action to the corporate NOA but it can be completely separate from it according to Siow v. the Queen.

Here is an article that actually explains the process clearly as opposed to the CRA's vague and murky circular:

www.newportgrp.com/news/2007/apr2007.pdf

Here is the relevant part:

Once you have resigned, the “two-year clock” starts running. Unless 
the CRA completes its process of assessing the corporation, finding itself 
unable to collect the tax from the corporation, and then issuing you a 
Notice of Assessment within the two-year period, you will not be liable.


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## Karen (Jul 24, 2010)

It seems to me that the first priority is to establish whether or not the OP is, in fact, a director of the company. I don't see how he could be if he has never signed anything to that effect. Years ago, I worked for a group of public companies incorporated under the B.C. Securities Act and occasionally prepared consent forms for newly-appointed directors to sign - if they didn't sign them, they were not directors.

Surely a person cannot be held liable for any responsibilities of a director if, in fact, he has never agreed to be a director.


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## Maxpower (Oct 29, 2012)

I phoned the CRA again today and the agent stated this was all based on a corporate tax assessment. I demanded that they assess me as director, as a tax lawyer suggested I do, so I would actually have something to fight against informing the agent that if that was not done they would be infringing on my right to due process. He told me that the debt had been pegged as unrecoverable and that he did not know why the refund was being held. He then suggested that it may have already been released and stated that I should call the individual tax line which was open for another half hour. He obviously just wanted to get rid of me because it is blindingly obvious none of that is true. This agents response was a complete 180 degree turn from what the prior agent had stated. Luckily I am recording the names of all agents I speak to because this entire fiasco is becoming ridiculous. 

The above agent did seem to take notice when I said I was going to file a service complaint against all of the individuals I have spoke to. Especially considering I caught him in a bald faced lie when he stated he did not know the name of the first agent I talked to when I asked him for it and I informed him that I had got her name from another agent just a few days prior and that he was assuredly looking at the exact same file that agent was. Confirming that to him by stating her name seemed to create an attitude change in the agent. The first time I asked for that name I was told there were only initials. I have no idea why anyone at that place would lie because they are obviously going to get caught up in it one way or another when they do. The corporate culture at that place is probably a complete disaster if these types of shenanigans are somehow considered acceptable.

I then went on to call the individual tax line, as the above agent suggested, and told the agent what his department had said to me a week prior.To call X number and ask them to remove the lien. He proceeded to tell me the number I gave him was not a CRA number. I told him that I was looking at it online and it certainly was. Then he told me I could not have that number and I told him "yes I do, I just gave it to you", at which point he put me on hold where I sat for about 10-15 minutes as the time went past 5:00 pm (obviously quitting time) and I was eventually disconnected. If that is a typical example of the service and professionalism that is displayed at the CRA offices then it certainly explains alot about this whole process and confirms all my prior worries.


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## Maxpower (Oct 29, 2012)

Karen said:


> It seems to me that the first priority is to establish whether or not the OP is, in fact, a director of the company. I don't see how he could be if he has never signed anything to that effect. Years ago, I worked for a group of public companies incorporated under the B.C. Securities Act and occasionally prepared consent forms for newly-appointed directors to sign - if they didn't sign them, they were not directors.
> 
> Surely a person cannot be held liable for any responsibilities of a director if, in fact, he has never agreed to be a director.


 A competent lawyer would never let it happen and having individuals familiar with the process of director appointments and consent would drastically decrease the chance it could happen, since they will not just skip the "organizational meeting" where director consents and other starting business is done. In a small family company there is a really good chance that those types of formal meetings, the ones where directors are normally appointed and business matters are settled, will just be skipped and, hopefully, sorted out more informally. In this situation it was novices all the way around, including, from what I have been told, the completing party, who worked for a registry search company. 

Some provinces require signed director consents as an explicit part of the incorporation process but that is not the case in B.C. In B.C. the completing party could fulfill all of his statutory duties as they are generally laid out, verifying that the necessary signatures are on all the necessary forms, and still have an end result of non consenting director(s) being submitted to the corporate registry. The forms that the incorporators and shareholders are required to sign are the "incorporation agreement" and the "articles" neither of which list directors in the simplest incorporation processes. Once the completing party sees those are all signed he can digitally submit the "incorporation application", which does not list the director(s), and the "notice of articles" which does list the director(s). The latter two are digital and therefore they are not signed by everyone and instead the completing party just puts his digital signature on them, which is an acknowledgment that he verified the other legal forms were signed, the ones that don't list the directors, and he has fulfilled his duties. Whoever decides what names are placed on the digital "notice of articles" as directors would be the one who decides who will be listed in the corporate registry as a director of the company.

If that person never tells the other individual(s) he listed them as director(s) due to not knowing that directors actually have statutory duties and it is not just another word for shareholder or owner then they may never know they have been been registered as a director of a company. If the company is run right they would know because they would prioritize a meeting to sort out the business of the company but if it is just a small informal company then it could easily be skipped. Considering the liabilities that can attach to directors it seems like a pretty major oversight in the B.C. legislation not to require that directors submit signed consents that are verified by the completing party before they can be placed in the "notice of articles" and submitted to the corporate registry but for some reason that is exactly how it works in B.C.


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## Karen (Jul 24, 2010)

That is absolutely incredible, isn't it? The B.C. company that I worked for certainly considered it compulsory to have directors sign consent forms. I can't remember whether or not we submitted them to the Registrar of Companies, but they were certainly inserted in the Company's minute book together with a directors' resolution authorizing the appointment. From what you have learned, it seems like you're saying that I could incorporate a company, appoint you as a director without your knowledge (even though we don't know each other at all), and you would have the legal responsibilities of a director. I'd be very interested in whether that would stand up in the courts, but I certainly understand that you're reluctant to go to that extreme. Please keep us informed as to how this is resolved.


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## Maxpower (Oct 29, 2012)

I phoned again today and when I asked why the refund was being held they claimed it was because of a corporate assessment. When I stated to the female agent that I am not a corporation and demanded they send an assessment to me personally (something I have read is statute barred due to the 2 year limitation on directors), in MY name, so I can object to it or they would be infringing on my right to due process I was told the agent was going to speak to a technical advisor and would phone me back. 3 hours later and no phone call received I called them back to learn there was no note left in the file by the female agent that never called back. After telling the new agent I was not a corporation he eventually proceeded to tell me it was being held not because of a corporate assessment but suddenly it is now because of a "memo to assess". That sounds like an administrative document to me, not a legal one. Obviously just another fabrication in a long line of fabrications. I no longer trust anything any of the CRA agents say.

I am going to request my files through the Access to Information Act and Privacy Act so I can actually show something to a lawyer. It looks like I have to do it formally since they refused to send it to me when I asked them. I will also keep taking down names and keeping notes so I have the option to file a long service complaint later if things keep going the way they are due to the fact I have not gotten the truth from any of these agents except maybe the one who eventually admitted he had no idea why the refund was being held.

I am amazed at how the CRA operates. It is obvious that for many of the agents at the CRA, not all agents though, honesty is meaningless in the workplace and playing on peoples ignorance is how things get done. I would absolutely hate working at that place and I kind of feel sorry for anyone who does.


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## Homerhomer (Oct 18, 2010)

I feel for you and your situation, but getting angry is not going to help you at all.
You expect a government agent to call you back in three hours? you need to reallign your expectations, secondly speaking to one of the thousands of clerks answering general inquiries is a waste of time, I know it can be difficult but you need to find someone who was assigned to this case, or who knows exactly how to deal with situations like this.


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## MoneyGal (Apr 24, 2009)

Maxpower said:


> The CRA is now telling me that I have to get the de-facto director to do a limited restoration of the company, which costs about $400, then send in a "Form 10: Notice of Change of Directors" to have my name removed as a director from the notice of articles, which I'm not sure is even possible, especially considering I have been told the company "records" have been lost.


The CRA told him exactly how to rectify this in the simplest, cheapest way possible. He said so in his very first post.


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## Maxpower (Oct 29, 2012)

Homerhomer said:


> I feel for you and your situation, but getting angry is not going to help you at all.
> You expect a government agent to call you back in three hours? you need to reallign your expectations, secondly speaking to one of the thousands of clerks answering general inquiries is a waste of time, I know it can be difficult but you need to find someone who was assigned to this case, or who knows exactly how to deal with situations like this.



I didn't expect her to call back quickly. I called them to get a timeline so I would have some idea when she would call but the agent I talked to said there was no note that anyone was going to call me back or that I talked to anyone at all. Plus she never did call.

At the local office that I called the very first day the secretary told me they would no longer accept my calls when I called back to get clarification the next day. The secretary then gave me the number to CRA collections. Every number I've got since then leads to a random agent. Today they told me they were holding the refund because of a "memo to assess" after telling me for the last week it was due to a 3 year old assessment they have against a dissolved corporation. The story changed right after I insisted that I am not a corporation and demanded they send me a NOA.

The big problem I see is there is no such thing as a "memo to assess" in the tax statutes so they are obviously talking about administrative paperwork that is probably 3 years old. That cannot be the basis for filing a certificate in the Federal Court of Canada for unpaid amounts which is the basis of their collection activities. They are just hoping I give up and go away. There is no way to fight or object or appeal to what they are doing because you can only fight something if it has a basis in law where guidelines for objections and appeals are set out. This is based on absolutely nothing and so it is just in legal limbo. I emailed my MP yesterday so maybe I'll luck out and he'll help. If not I'll go through the Access to Information Act and Privacy Act so I can actually show something to a lawyer. The CRA said they wouldn't send me any documents when I asked them today so that is my only option. With all their different stories I have to verify everything they are saying with a lawyer. No matter what though there is absolutely no way a "memo to assess" has created a legitimate debt that I owe to the CRA. They may wish they could create binding debts with their administrative memo's but I guarantee they can't.


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## Maxpower (Oct 29, 2012)

After reading this article:

http://www.thestar.com/news/canada/...-employees-and-why-some-still-have-their-jobs

I am really starting to wonder what is going on. What is happening may be a serious offense. If there are no grounds for what is occurring, and I am now certain there aren't, then, other then the amounts involved, there are similarities between what is occurring in my case and what the crook above was doing. For all I know the case leader is attempting to steal the refund. It is bad when my dealings with the CRA has me wondering if I may be dealing with a crook, isn't it? On "My Account" on the CRA website there is absolutely no indication of any alleged debt whatsoever. My statement of account lists a very large refund and nothing else. Pretty soon I am going to start contacting newspapers and giving them the names of the original agents I had contact with. May not be a big story but if there is any malfeasance someone may bite, especially considering how unpopular the CRA is rapidly becoming.


Someone from the local MP's office for my region e-mailed me on Friday morning asking for a consent so they can deal with the CRA on my behalf. I signed it and put in these questions for them to ask on my behalf:

1)What specific legal document, assessment or other, does my alleged debt originate from and exactly how do I object to it.

2)Why was there a lien put on my refund?

3)Why was I informed I could not call my local tax office?

4)Is there a registered certificate in the Federal Court of Canada for unpaid amounts in my name?

5)If not under what exact statute are you proceeding with your collections action against me by seizing my tax refund?

6)Isn't the alleged debt statute barred due to the fact I have not been an alleged director for well over 2 years?

7)Why was I told that there was a collection action against me *personally* based on a 3+ year old corporate assessment against a company that was dissolved in 2007?

8)Why was I then later suddenly informed the collection proceeding was based on a "memo to assess", in contradiction of everything I was told up to that point?

9)In what exact statute is there mention of a "memo to assess" so I can understand how it applies in the debt collection process?




Not too long after I e-mailed it, the representatives office e-mailed back and said they would contact me within a day or two. 

Who knows maybe I will actually get some answers now.

Then the Taxpayer's Ombudsman office phoned due to reading a comment I submitted to their website where I described what had been happening. The person who contacted me stated I should submit the "RC193 - Service-Related Complaint" form to Revenue Canada's service complaints department and that I had valid points, she did not know what a "memo to assess" was either. I told her I did not trust anyone at CRA now, which I've since learned translates to the person in control of my file due to the heirarchy implemented there, and asked if the service complaints department is any better. She seemed to think it was and said that if my concerns were not addressed at the end of all of this to make a complaint directly to the Ombudsman's office. I am certain this will all be cleared up but I am going to make a service complaint anyway because one of the reasons this whole fiasco is occuring is because not enough people do it, and now some CRA agents, and collections officers, appear to believe they can unilaterally do whatever they want.


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