Milot Law continues to file appeals in the Tax Court of Canada in respect of the Universal Barter Group and the Liberty Wellness Initiative Foundation. After several case management conferences with the Court, and the Department of Justice, the parties are working towards a timetable for the discovery process. The Taxpayers take the position that the UBG program was legitimate and was supported by a tax opinion and a comprehensive valuation report.
Milot Law is also acting for a number of Taxpayers formerly involved in the Universal Donation Program, the Universal Healthcare Group Inc. and the Destiny Health and Wellness Foundation. We are currently organizing a second group of taxpayers to proceed to the Tax Court of Canada. We understand that settlement offers will be made at the CRA Appeals level for most taxpayers; this will involve allowing the cash donation and waiving a significant portion of the arrears interest. No amount will be allowed for the gift-in-kind.