December 25, 2022

The Honorable Diane Lebouthillier, P.C., M.P.

Minister of National Revenue
7th Floor -555 Mackenzie Avenue
Ottawa, ON 
K1A 0L5.

Office of the Prime Minister

Prime Minister Justin Trudeau
80 Wellington Street
Ottawa, ON
K1A 0A2

Mary Ng (Minister of International Trade, Export Promotion, Small Business and Economic Development)
16 Esna Park Drive
Unit 107
Markham, Ontario
L3R 5X1

Monica Biringer (Tax Court of Canada)

200 Kent Street
Ottawa, ON
K1A 0M1

Re: Allegation of Fraud/ Misfeasance with CRA Quick Method

Dear Honorable Minister of Revenue, Prime Minister and Honorable Tax Court Justice Monica Biringer
and others:

This letter deals with a very serious issue which occurred over the course of 3 years starting May 2020. It
deals with the transfer of assets from a 4x companies located in Ontario to a Federal Corporation located
in Dorval Quebec- #12118424 Canada Inc.

The transfer of $400,000 in electronics from 4x companies located in Ontario to a Federal Corporation
located in Quebec. The transfer of assets or sale, would result in the applicable HST to be charged and a
‘quick method’ rate to be remitted to the Federal Government.

4x sole proprietorships located in Ontario sells $400,000 of electronics to a corporation located in Dorval
Quebec.

SALE FROM “ONTARIO” COMPANIES TO “QUEBEC” CORPORATION

$400,000 x 0.05 or 5% [HST] = $20,000 HST charged by companies located in Ontario during
sale. A company charges the applicable GST,
not HST since Quebec has the QST.

REMITTANCE OF TAXES TO FEDERAL GOVERNMENT

$400,000 x (0, 2.8%)= $11,200

As shown in the aforementioned example, the companies located in Ontario charges 5% during the sale –
Charge 5% or $20,000.00 and when its time to remit the taxes to the federal Government, they receive
2.8% credit, so they remit 0 and receive an additional 2.8% or $11,200. The reason the company located
in Ontario doesn’t remit anything to the Government of Canada is because their initial supply was taxed at
13%.

In this case, we had CRA employees who erroneously charged 5% to the companies located in Ontario +
penalty for the transaction. This is incorrect and a company does not remit the total taxes it collects. Why?
Under the traditional method of Accounting a company collects the HST, then deducts HST paid out and
certain ITC.

In the ‘quick method’ of accounting, the company collects the HST, then remits a percentage of the HST
collected.

Traditional Method of Accounting:

Collect HST, then deduct HST paid out on supply-13%, Input Tax Credit, Business write-offs,
taxes paid on items needed to carry on business (promotion material, advertising, etc)

Quick Method of Accounting:

Collect HST, then remit a proportion of HST collected to Government [cannot deduct HST paid
out on supply-13%]

In this case, the CRA tried to charge the business owner approximately $32-$35K in HST taxes without
understanding that a business does not remit the total taxes it collects. If you have a good accountant,
sometimes business write-offs, ITC’s could, or taxes initially paid out on supply reduce the HST obligation
to the Government to $0.

In this case the matter was arbitrated directly to the Tax Court of Canada for a ruling which took close to 2
years. After the ruling, which was clearly wrong – [Tax Court of Canada didn’t even know the Quick
Method of Accounting], the Corporation in Quebec REFUNDED the transaction (Returnable Goods-
Goods were returned in Ontario), based on the fact that your Canada Revenue Agency FAILED to
understand the QUICK METHOD OF TAXES, pursuant to:

Returnable Goods
https://www.canada.ca/en/revenue-agency/services/tax/businesses/topics/gst-hst-businesses/
charge-collect-special-cases.html

This was a huge loss of future taxes to your Government (loss on the initial transaction- which will be
refunded- LOSS $400k x 5%= $20,000.00 LOSS, loss on the resale of electronics from company in
Quebec to customers in Quebec - $400,000 x 4 (markup of 400%- buy a battery for $1, sell for $4) x
9.975% QST= $159,600.00 LOSS

This reminds me of something very similar to the COVID19 pandemic, when you had individuals working
in law enforcement and military capacities that misunderstood in Brampton, Ontario that an individual they
were investigating had a ‘biological weapon’ and started the COVID19 pandemic resulting in higher
inflation, prime lending rates, etc. recession of certain G20 countries. This was a DIRECT result of having
individuals working in our municipal, provincial, and federal agencies who may have suffered from some
type of mental disorders and who should have not even been close a government agency, etc. due to
these mental disorders, etc.

This in essence, is a failure on the part of your Government of Canada to have well-trained CRA
employees who know how to administer likely the largest revenue stream for the Government of Canada
and understand very simple tax collection methods. It is also a failure on the part of Her Majesty the
Queens representatives and l would imagine that there are many other small business owners who have
either closed their businesses based on being erroneously charged taxes

I would imagine the individuals working at the CRA didn’t know what they were doing, respectively.

This has resulted in transaction being ‘refunded’ or ‘voided’ based on the fact that the companies located
in Ontario WILL NOT ABSORB THE TAXES 13% IT INITIALLY PAID OUT ON SUPPLY!!!, BY
REMITTING ALL 5% TO YOUR GOVERNMENT AND ABSORBING A LOSS OF 13% + 18% DUTY IT
PAID OUT FOR THE GOODS (BATTERIES/ ELECTRONICS) FROM P4C GLOBAL, PNE ENTRPRISE,
BSD WIRELESS, BSW WIRELESS.

When a company located in Ontario imports batteries/ electronics in my case and pays out 13% HST and
18% Custom Duty= 31% (collected by UPS or Fed Ex when package is dropped off), then charges 5%
HST to a customer located in Quebec, then has to REMIT all 5% to the Government of Canada, without
getting the initial 13%+18% back (traditional method of accounting) or % (quick method of accounting).
The company would lose approximately 31% on the sale.

Here are the dates:

May 1, 2020- Quick Method of Taxes Administered

June 16, 2021- Notice of Confirmation HST

Aug 19,2021- Notice of Appeal filed WEB785087

Sept 9, 2021- Tax Court sent letter regarding FEE WAIVER (need to confirm income)

Sept 11,2021- Leonard sent fee waiver+ odsp statement sent

Oct 29, 2021- called indicated "not complete"- based on not having fee waiver finalized

November 1, 2021- Served Crown Marinel Matei 120 Adelaide St

Sincerely,

Leonard Ro, MBA, CPPMO