Canada Revenue Agency Compliance Invoicing
This is about Invoicing the CRA for your work complying with their regulations concerning tax administration and audits.
First off, let me state that I am not an accountant or a lawyer, I am a business owner of a firm that performs research and development (computer hardware/software, electronics and physics) and another firm that operates in the entertainment industry. I do have to deal with intellectual property rights, NDA’s, contracts, patent and copyright law and have done so for the last 38 years in the course of operating my businesses as well as my positions as an engineer, engineering manager or R&D director in other companies. That by no means makes me an expert, I’m just a business owner who has had to operate within specific ”legal” frameworks and who has gained ”some” experience in these areas. So, always check with your accountant and a lawyer before you do anything or at least do your own research. Consider this post to be opinions peppered with instruction, facts and a number of CRA/BOC links and I am certainly not telling you what to do, but it appears we all have options.
I am starting this thread because I am on my sixth audit since 1996 and every time but once (I made a mistake that reduced my refund by about $2k), the CRA ended up refunding my companies more than I initially claimed. Revenue Canada pisses me off, as it does so many other people but during this present audit I decided to examine filing formal complaints for harassment. One of my past audits was actually a ten year audit from 1996 to 2005 which took roughly six months to complete in 2005/2006. The result of that $100k waste-of-taxpayer-money was that the CRA refused to prosecute criminal malfeasance or fraud charges against government ministers and a university due to the scandal it would have created (there is a court case), but nothing changed in my taxes. They had to pay me the original refund based on my books, receipts, ledgers and their findings during the audit. Still, a waste of taxpayer money and criminal dereliction of duty by the CRA all the way to the minister of finance according to the manager at the CRA office.
During my search I found out additional information that may be beneficial to many. All links in this document are links relating to the Canada Revenue Agency (CRA) or the Tax Ombudsman at the Bank of Canada (the BOC, one of the most heinous criminal organizations, just like the Federal Reserve) and all PDF files I have linked are on the related websites and can be acquired through the HTML pages if you don't want to access the PDF’s directly. I am not finished researching yet, but what follows is the information I have found so far. If anyone has additional information on tax regulation compliance cost submission and invoicing, please submit it in this thread.
In the United States similar rules/laws may apply. I hope that people from the US research this possibility as well, I can just imagine what would happen if the IRS/FED received 100+ million complaints, invoices and FOIA requests. I hope someone will make a companion thread based on the IRS, the FED and the US.
First off, the item I think most people will be interested in, is the probable ability for the personal taxpayer and/or business to invoice the CRA/Revenue Canada for Compliance and Audit costs. Now what are the reasons for invoicing the CRA according to the BOC?
1. Compliance: To comply with existing tax laws and collect or dispense revenues as prescribed by the existing legislation. In other words, the direct time and costs applicable in real terms for maintaining records and executing the requirements of compliance on behalf of the CRA, even when not under an audit.
2. Audit Costs: Those costs directly related to an Audit by the CRA, meaning time spent in the collection and collimation of records, ledgers, filing, accounting or legal costs, interpretation of tax law, meetings both direct and over the phone. Again, costs in real terms.
3. The storage of records relating to compliance with the tax code and the CRA or the criminal code relating to the non-destruction of evidence relating to the CRA or its investigations.
The CRA generally doesn't like to inform people or businesses that you can apparently bill them back for the hoops they make you jump through, but there is a BOC tax website that gives you a bit of the information. Funny that this information comes from the Bank of Canada. Who would have thunk it, eh, criminals giving their victims information or maybe it’s just a red herring?
Taxpayer Digest, Bank of Canada Menu HTML
Taxpayer Digest, Bank of Canada PDF
And directly from the Canada Revenue Agency site;
Taxpayer Bill of Rights HTML Page
Taxpayer Bill of Rights Document PDF
As I said, pretty funny that the Taxpayer Ombudsman's Office runs out of the Bank of Canada, criminals controlling criminals. It kind of let's you know, in no uncertain terms, whom the CRA works for and it’s not the Canadian government (meaning the people), but rather the Bank of Canada (literally owned, operated and controlled by the IMF and Goldman Sachs). That means that the CRA (Revenue Canada or the Canadian Revenue Agency) is a collection agency for the IMF in a very literal sense and has been provided the ability under legislation to ”legally“extort Canadians. Anyway, you can send your tax complaints to the ombudsman’s office at;
Contact the Tax Ombudsman HTML Page
And/or you can contact the Canadian government minister’s office supposedly in charge of the CRA at;
Contact the Government Minister in charge of the CRA HTML
But you have to get the CRA's complaint procedure information and fill out their forms of course found below if you want to lodge a complaint after they deny your invoice (which they probably will in a knee-jerk reaction);
CRA Instructions for a Complaint PDF
CRA Form 193 Complaint PDF
So, following the explanation of the "Taxpayers Digest" summary and existing legislation and since I have been keeping a rough track record of my expenses over the years dealing with CRA audits and the legislative requirements to keep records (compliance), I have come to the conclusion that since 1996 my accumulated costs in audits and legislative compliance requirements are more than $65,000 (remember this is for roughly 15 years, the CRA keeps records for 20 years) for my older corporation.
Now, what does the Tax Ombudsman actually say about Taxpayer Rights from their guide?
“Article 10 - You have the right to have the costs of compliance taken into account when administering tax legislation.
To prevent tax compliance from becoming an unreasonable burden, costs associated with meeting one’s tax obligations must be taken into account by the CRA. These costs can include the costs associated with preparing and filing one’s taxes, costs that business owners must incur in order to collect taxes on behalf of the government, or even costs associated with dealing with the CRA such as providing it with information or interpreting information it provides. In order to keep these costs low, the CRA is working to stream line its processes so that the administrative costs associated with taxation are not a hardship.”
In simple terms, ALL the costs of compliance must be taken into account by the CRA. I gave a very simple analogy to the auditor today of her interpretation (not the BOC interpretation); Company B is required to collect royalties for Company A. Company B may or may not hire an accountant to manage the collection of royalties and their transfer to Company A. The accountant or Company B however must work for free on behalf of Company A and do everything Company A demands at no cost to Company A. Now just replace Company A with CRA, Company B with your company and accountant with your name.
Forced work without pay is slavery. Legislated work without pay is slavery through extortion.
Invoicing the CRA
Since the government “seems” to have this invoicing/costing/complaint procedure in place that allows one to question not only the validity of the operation of the Canada Revenue Agency but also appears to provide the taxpayer the ability to obtain financial relief from the Canada Revenue Agency for Regulatory Compliance and Audits, I would encourage everyone in Canada that is a taxpayer to exercise their legal rights. Meaning file complaints with the Tax Ombudsman when applicable and send invoices to the CRA for your compliance and audit costs when applicable. Invoices should specify the number of direct hours used for compliance and/or audit, the hourly rate (be accurate) and expenses related to compliance and/or audit. Costs should be broken down by year (rows), specific costs (columns) and as well include any interest (I used 6% which is pretty typical) so the CRA can understand how you determined your costs.
The CRA gives an analysis of the costs for regulatory compliance (without an audit) pertaining to small businesses, which for domestic corporations is about $3,590.00 on average per year. You can find that data on the CRA site here;
CRA Compliance Costs
But who is supposed to pay these costs? Can I bill you to do my taxes for me? I don’t think so. Can I send you out to do the taxes for a company where I collect the fee but don’t pay you? I don’t think so. Should my customers pay me to perform the CRA’s work? I don’t think so. Should the CRA pay for it’s own work and the costs of compliance of their own program? Yeah, I think so and it seems the mechanics are in place to do just that, bill them for the work that the CRA demands we all do through legislated extortion. So I started putting together my invoices based on what I have read so far from the CRA and BOC websites.
Prior to 2010 the tax rate on these CRA based costs would be 5% GST and 2010 or after the applicable tax rate would be 13% HST. GST/HST may or may not apply, I haven’t received confirmation yet but the invoice spreadsheet is shown for a business with a tax number, in a manner that a business would charge a client company in Canada. A sample of one of my company's invoice spreadsheets with some altered numbers for mild obfuscation purposes is below. It is more than reasonable for 15 years of compliance and audits for a business (regardless, the CRA will recognise this spreadsheet :-O oh noes ). I have not included the costs of the storage of compliance documents or the costs involved in storing CRA related evidence concerning the 1997-2001 $150 million tax and public funds frauds in which I blew the whistle, since the documents are stored in twelve different locations and a legal ”instrument” has been maintained to trigger the release of the documents into the public domain (dead manâ€s switch);
The Invoice Spreadsheet
Company Name - Business Number
Normal Compliance Audit Compliance w/o interest w interest
Year Auditor Time Cost/hr Expenses Time Cost/hr Expenses Subtotal A Interest Subtotal B GST Total
1996 none 36 $30.00 $0.00 0 $30.00 $0.00 $1,080.00 $1,036.80 $2,116.80 $105.84 $2,222.64
1997 none 36 $30.00 $0.00 0 $30.00 $0.00 $1,080.00 $972.00 $2,052.00 $102.60 $2,154.60
1998 xxxxx 36 $30.00 $0.00 27 $30.00 $0.00 $1,890.00 $1,587.60 $3,477.60 $173.88 $3,651.48
*1999 none 36 $30.00 $42.00 0 $30.00 $0.00 $1,122.00 $875.16 $1,997.16 $99.86 $2,097.02
2000 xxxxx 36 $30.00 $0.00 24 $30.00 $0.00 $1,800.00 $1,296.00 $3,096.00 $154.80 $3,250.80
2001 none 36 $40.00 $0.00 0 $40.00 $0.00 $1,440.00 $950.40 $2,390.40 $119.52 $2,509.92
2002 none 36 $40.00 $0.00 0 $40.00 $0.00 $1,440.00 $864.00 $2,304.00 $115.20 $2,419.20
2003 none 36 $40.00 $0.00 0 $40.00 $0.00 $1,440.00 $777.60 $2,217.60 $110.88 $2,328.48
2004 none 36 $40.00 $0.00 0 $40.00 $0.00 $1,440.00 $691.20 $2,131.20 $106.56 $2,237.76
2005 none 36 $50.00 $0.00 0 $50.00 $0.00 $1,800.00 $756.00 $2,556.00 $127.80 $2,683.80
**2006 xxxxx 36 $50.00 $0.00 292 $50.00 $14.00 $16,414.00 $5,909.04 $22,323.04 $1,116.15 $23,439.19
2007 none 36 $50.00 $0.00 0 $50.00 $0.00 $1,800.00 $540.00 $2,340.00 $117.00 $2,457.00
2008 none 36 $50.00 $0.00 0 $50.00 $0.00 $1,800.00 $432.00 $2,232.00 $111.60 $2,343.60
2009 xxxxx 36 $50.00 $0.00 27 $50.00 $0.00 $3,150.00 $567.00 $3,717.00 $185.85 $3,902.85
2010 none 36 $60.00 $0.00 0 $60.00 $0.00 $2,160.00 $259.20 $2,419.20 $725.76 $3,144.96
2011 none 36 $60.00 $0.00 0 $60.00 $0.00 $2,160.00 $129.60 $2,289.60 $686.88 $2,976.48
2012 none 36 $60.00 $0.00 0 $60.00 $0.00 $2,160.00 $0.00 $2,160.00 $648.00 $2,808.00
2013 0 $60.00 $0.00 0 $60.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00
612 $42.00 370 $14.00 $44,176.00 $17,643.60 $61,819.60 $4,808.18 $66,627.78
My apologies if the above spreadsheet didn’t format quite right and if you need one for your own purposes as an example, I can send you a CSV (no formulas), Excel, Lotus or Quattro file. As you can see the cost of regulatory compliance is about $1,500 per year average during normal compliance years for my above company. Audit compliance years are higher due to increased time costs and expenses.
To find out where to send your invoice to the CRA please find the nearest CRA office to your location in the following link, contact them and send your invoice if applicable;
Contact the CRA for Mailing Locations HTML
As an example, in Ottawa, Ontario the CRA office is at;
Ottawa Tax Services Office
333 Laurier Avenue West
Ottawa ON K1A 0L9
I would also suggest that you send your invoice by regular post, but obviously faxing is an option (or both fax and mail to be sure and have a record or there’s registered mail), there is no e-mail option that I am aware of at present. In addition, the Tax Ombudsman may be able to provide a different or more viable address.
One very important note, the CRA likes the term ”submission” to the tax program as ”voluntary compliance” which is very interesting terminology and of course a lie. It means that YOU are willing to pay for their program or do the CRA’s work for them at no apparent cost to the CRA. This is paramount to ”tax slavery” and is reinforced by the simple fact that you are ”obligated” under both financial and/or criminal penalties to comply in an allegedly ”voluntary” program, which would mean that the tax program is based on legalized extortion and slavery. To mix the words ”voluntary” and then ”obligated” with ”penalties” makes no sense, this is an oxymoron. An obligation to perform work for a third party without payment for said work, is slavery. Fraser University has analysed personal tax compliance and made the statement that the average person requires 5.65 hours to complete their tax return. Who pays this cost for tax compliance other than the taxpayer with no financial benefit (slavery), doing the CRA’s work?
1. (Law) the state or condition of being a slave; a civil relationship whereby one person has absolute power over another and controls his life, liberty, and fortune
2. the subjection of a person to another person, esp in being forced into work
3. the condition of being subject to some influence or habit
4. (Business / Industrial Relations & HR Terms) work done in harsh conditions for low pay
If you do not get any satisfaction from the CRA or the Tax Ombudsman after submitting your invoice for payment, you may wish to file a Freedom of Information (FOIA) request with the CRA. Please be specific in the information request stating your name, birth date and SIN or in the case of a business, its legal corporation name, business number and creation date, so that the CRA cannot legally obfuscate or delay in their response. They MUST answer an FOIA request within 30 days by law (unless it's been changed), otherwise if they do not answer, the CRA is liable for fines and sanctions for breaking the law. You can make your request by mail and include a $5 cheque or money order as required by this process to;
Canada Revenue Agency
Access to Information and Privacy Coordinator
45 Rideau Street, 6th Floor
Ottawa, Ontario K1A 0L5
Other Telephone: 1-866-333-5402
Please remember that a $5 fee to perform an FOIA Request can create costs for the CRA in the area of 20 to 1000 times that original $5 and a lot of legal headaches with each and every request. Follow the instructions provided in the link. The email address is for information only, you cannot make an FOIA Request by fax or email. You can get the FOIA Request information and forms here;
FOIA Request Information HTML
FOIA Request Form PDF
I have included a text that might be used for the FOIA request and placed in the info request box (write to suit);
Any and all information, including classified information, pertaining to myself, your name here, your SIN here, your birth date here, that is contained in all or any files including but not limited to, paper files, microfiche or in electronic or other format that are held by Revenue Canada, also known as the Canadian Revenue Agency, also known as the CRA. This information request also includes but is not limited to any information transmitted or received between Revenue Canada/the CRA and any other organization, institution, agency or foreign government, internal to, external from and/or operating with or in parallel to, the government of Canada.
FOIA requests can be a dangerous tool. If the CRA has information in their files that is derogatory, defaming or slanderous/libelous to you or your company, the CRA can be sued directly and/or the information can be corrected. An FOIA request if worded properly requires the legal release of ALL information specified in the request except where prohibited by law, which generally means information is not released that could be factually construed as being a threat to national security. Since the CRA is a subsidiary corporation that works directly or indirectly for the IMF, this kind of request is unlikely to involve national security as we are dealing with a parent corporation's collection agency, not a government.
An Aside - Once upon a time while the government was changing over to graduated driving, my wife was taking her driving test and they illegitimately failed her so that they could stick her into graduated driving. She went to the front desk to make a new appointment within 7 days as per the MTO contract and they told her she would have to wait three months for a new test which was a breach of contract and that would have placed her into graduated driving. I then had a meeting with the manager of that MTO office, recorded the entire conversation and he went batsh*t on me for questioning his authority, but he did admit to the breach of contract. I contacted the Director of the MTO at Keele Street in Toronto and gave her an option to either give my wife her contractually obligated driving test within seven days or I would have the tape played on the radio on Q107, have the transcript printed at the Sun Newspaper and then the MTO Director could deal with the 10,000 pissed-off new-driving-test-people that also had their contracts breached. She contacted me one day later and gave my wife a new driving test appointment three days later. I then released the information into the internet, I didn't put it on the radio or in newspapers as agreed.
YOU can make a change all on your own, even if it's small and we can all make a much larger change if we work together.
Canadian politicians signed the UN Abolition of Slavery Convention/Treaty on 7 September 1956 and was allegedly ratified 10 January 1963. However, there is nothing in the 1982 Constitution Act of Canada that makes slavery illegal, but I have to wonder if the constitution is even worth the paper it was written upon. However, under international law, supposedly a treaty is a valid adjustment to any national law once ratified. So what can we gain from this information? Well, that Canada as a colony has been a signatory to international law making all forms of slavery illegal and that this treaty was given ”royal assent.” The treaty can be found here;
Supplementary Convention on the Abolition of Slavery, the Slave Trade, and Institutions and Practices Similar to Slavery
UN Abolition of Slavery Treaty - Status
Most people think of slavery as being only a white on black thing (every race has participated in slavery), this may be one facet, but the definition of slavery encompasses many other areas such as being a debt slave, forced labour for no payment, sexual slavery and abuse or working the land which you do not own for a land owner with no or very low payment. Since the government and ultimately the queen of England “owns” Canada (if you do not pay your taxes you will find that out very quickly), you are working the land which you do not actually own even if you think you purchased the land “legally.” You may occupy the land based on a finite lease that exists only so long as the government does not want your land and that you pay fealty in the form of taxes to the government or the crown.
The CRA (Revenue Canada) also participates in slavery, that being forced work for no pay in compliance with (subjugation to) the tax laws and uses extortion to promote the agenda of their criminal collection agency (even if the BOC website says otherwise, I am relating the CRA attitude). When I spoke to the auditor about this the other day, she claimed that tax refunds were entitlements, the wrong word actually. What she intoned is paramount to saying that you must do your taxes for free on behalf of the CRA so that you can receive back the money you paid into the system that was yours in the first place. How ef’d up is that? From this I can only imagine that any government employee has been programmed and really does not have the capacity for critical thought or maybe they are afraid of losing their jobs, another form of slavery through extortion.
What can we conclude from the fact that Canada is a signatory to international law abolishing all forms of slavery? What we get is that the operation of the CRA which uses extortion to force unpaid labour by citizens (or any person) is illegal under international law. We also find that unpaid property taxes that allow for the removal of the rights to property, which has been paid for by a citizen, is also illegal. In fact, almost every aspect of the government’s operations that require taxes, levies or licences utilize some form of extortion (the slaver’s whip) to force subjugation to the government (slaver), is illegal, according to both treaty and the 1793 and 1834 Abolition of Slavery laws in Canada.
The true definition of freedom is the ability to say NO to anything you do not agree with or want to do and no one can compel or force you to change your decision. The opposite of freedom is slavery. You either have freedom or you are a slave. There is no middle ground, as you cannot say NO to some things and be a little free. It’s like being pregnant, you either are or you aren’t. You can’t be a little pregnant or sort of not pregnant when you are. You cannot define being free as the ability to hang the picture of your choice in your living room, when if you do not prostrate yourself before the government by paying all of their taxes and levies, they can take your house and property. What the government and the BOC/CRA provides to people and business is not freedom, it IS however most definitely subjugation and slavery through extortion.
As I said in the beginning of this thread, I am tired of these CRA ”people,” their controllers/handlers and their harassment. The IMF and international bankers through governments have been conducting a war against us, the men and woman who are just trying to make a living as well as businesses. The CRA is one of the IMF’s tools and I think it's about bloody time we take it to their doorstep in at least complaints, invoices and FOIA requests. Civil disobedience, as someone suggested before, is all well and good, but it’s passive and it’s laughed off by the government just as they laughed off the billions in tax and public funds fraud during the HRSDC hearings (I wish I could post the video). What I am doing here is taking an active stance and meeting ”legalized” extortion and slavery with legal ”aggression.”
Can you imagine what would happen if the government and the IMF/Bank of Canada/CRA/Ombudsman/Minister for the CRA received eight to twelve million private taxpayer/business complaints, invoices and FOIA requests? I can ;-) Mine are all going out November 22, 2012 to the proper agencies. Some people will say, "oh noes, you'll be labeled as a domestic terrorist." Well, CSIS has already done me that dis-service, all because I worked for a foreign military, saw the US/Iraqi weapons deals for the invasion of Kuwait and because I know about the ”alleged” $150 million Canadian government/university tax/public funds frauds and other dirty dealings involving ambassadors as well as the CRA. Sh*t happens.
Time to get pro-active people. Lead, follow or get out of the way.
Cheers - Dave
“Shut it down, shut it all down” The controller in the movie ”Dark City”