appeal officer refuse meeting the_pros_are_in_the_know.pdf

https://www.cpacanada.ca/en/connecting-and-news/blogs/tax-blog/2014/November/Tax-appeals-CRA-limits-in-person-meetings Page 1 of 2 Mar 25, 2015 02:37:33PM MDT The pros are in the know cpacanada.ca Tax appeals: CRA limits in-person meetings Resolving tax appeals: CRA practice limits face-to-face meetings Gabe Hayos, FCPA, FCA, ICD.D November 12, 2014 In this Tax Blog post, Gabe Hayos, Vice President, Taxation, for CPA Canada, asks why Canada Revenue Agency’s appeals officers don’t accept face-to-face meetings to resolve disputes more often. Share Facebook Twitter Linkedin Google Plus Email Canada Revenue Agency’s (CRA) appeals officers are supposed to resolve tax disputes impartially, objectively and expediently. Many tax practitioners believe that in some cases resolving tax disputes can be achieved most efficiently in-person, and they have raised concerns about how frequently appeals officers turn down their request for a face-to-face meeting. Why don’t appeals officers accept these meeting requests more often? The Appeals Branch has advised that it has constrained resources. Limiting face-to-face meetings is intended to help the branch process its current backlog of appeals. And we’re told that appeals officers communicate via phone, written correspondence and sometimes face-to-face, depending on the information that needs to be communicated. Ultimately, all appeals decisions are documented in writing. Well-written submissions are the most important basis of appeals decisions. The Appeals Branch general view is that meetings that are requested before a written submission are not an efficient use of an appeals officer’s time, and so they are frequently denied. Practitioners have expressed the view that an initial face-to-face meeting is often the only way that they can be assured that the appeals officer understands the reason for the taxpayer’s filing position. In the appropriate circumstance, meeting face-to-face can be the most efficient way to settle an appeal. The Appeals Branch has indicated that appeals officers would agree to meet face-to-face if: a file is complex or the appeal is based on a provision that permits a range of technically correct applications

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https://www.cpacanada.ca/en/connecting-and-news/blogs/tax-blog/2014/November/Tax-appeals-CRA-limits-in-person-meetings

Page 1 of 2 Mar 25, 2015 02:37:33PM MDT

The pros are in the know cpacanada.ca

Tax appeals: CRA limits in-person meetings

Resolving tax appeals: CRA practice limits face-to-face meetings

Gabe Hayos, FCPA, FCA, ICD.D

November 12, 2014

In this Tax Blog post, Gabe Hayos, Vice President, Taxation, for CPA Canada, asks why Canada RevenueAgencys appeals officers dont accept face-to-face meetings to resolve disputes more often.

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Canada RevenueAgencys (CRA)appeals officers aresupposed to resolvetax disputesimpartially,objectively andexpediently. Manytax practitionersbelieve that in somecases resolving tax

disputes can be achieved most efficiently in-person, and they have raised concerns about how frequentlyappeals officers turn down their request for a face-to-face meeting.

Why dont appeals officers accept these meeting requests more often? The Appeals Branch has advisedthat it has constrained resources. Limiting face-to-face meetings is intended to help the branch process itscurrent backlog of appeals. And were told that appeals officers communicate via phone, writtencorrespondence and sometimes face-to-face, depending on the information that needs to becommunicated.

Ultimately, all appeals decisions are documented in writing. Well-written submissions are the mostimportant basis of appeals decisions. The Appeals Branch general view is that meetings that are requestedbefore a written submission are not an efficient use of an appeals officers time, and so they are frequentlydenied.

Practitioners have expressed the view that an initial face-to-face meeting is often the only way that they canbe assured that the appeals officer understands the reason for the taxpayers filing position. In theappropriate circumstance, meeting face-to-face can be the most efficient way to settle an appeal.

The Appeals Branch has indicated that appeals officers would agree to meet face-to-face if:

a file is complex or the appeal is based on a provision that permits a range of technically correctapplications
https://www.cpacanada.ca/en/connecting-and-news/blogs/tax-blog/2014/November/Tax-appeals-CRA-limits-in-person-meetings

Page 2 of 2 Mar 25, 2015 02:37:33PM MDT

a file is complex or the appeal is based on a provision that permits a range of technically correctapplications

the appeals officer is responding to a complaint on the conduct of CRA officials on the filethe file is headed to tax court and the practitioner insists on a meetingthe appeals officer believes that the credibility of the taxpayer is an issue and wants to assess

that credibility in person

About the Author

Gabe Hayos, FCPA, FCA, ICD.D

CPA Canada Vice President, Taxation

Copyright 2015 CPA Canada