Nov 24, 2025 12:27:21 PM - Key Takeaways Inconsistent cross-border descriptions created tension between the structure’s design and its economic reality. Risk and benefit flowed to different entities across jurisdictions, shapin...
Feb 6, 2026 11:47:15 AM - Key Takeaways The appeal failed because the parties continued after the win path had closed. The hearing created no real opportunity or upside. The case continued without a clear stop-point, turning...
Strategy and Outcomes
Feb 21, 2025 6:49:16 PM - This article is part of CFO Tax Dispute Insights, Counter Tax Litigators LLP’s executive series delivering strategic guidance to private businesses and CFOs on navigating high-stakes CRA disputes, rea...
Feb 11, 2024 7:30:00 AM - Executive Summary A recent ruling by the Federal Court of Appeal in Gestion M.-A. Roy Inc. v Canada, 2024 CAF 16, underscores a growing risk in corporate tax planning: life insurance premiums paid by ...
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