Mar 5, 2025 3:27:19 PM - This article is part of Counter Tax Litigators LLP’s "Private Enterprise Tax Risk & Dispute Series," delivering strategic guidance to finance leaders monitoring and navigating high-stakes tax risks,...
Mar 5, 2025 3:27:19 PM - This article is part of Counter Tax Litigators LLP’s "Private Enterprise Tax Risk & Dispute Series," delivering strategic guidance to finance leaders monitoring and navigating high-stakes tax risks, c...
Feb 28, 2025 3:26:57 PM - Key Takeaways Data shows a surge in improper CRA reassessments leading up to March 31, driven by TEBA targets and March 31 fiscal year-end pressures. CRA audits, driven by TEBA targets, prioritize rev...
Feb 21, 2025 6:49:16 PM - Key Takeaways for Leaders A CRA audit is not just a process - it's a conflict, unfolding in real-time. Leaders who treat it as routine compliance fail to recognize the trends, the CRA's approach, and ...
Feb 14, 2025 9:15:00 AM - Key Challenge: Clarifying GST/HST Supply Classification Integrated Transactions: Tax professionals should proactively evaluate whether elements of a purchase are truly independent or part of a single ...
Feb 6, 2025 7:15:00 AM - The Federal Court of Appeal’s (“FCA”) decision in Enns v. Canada[1] clarifies how “spouse” is defined for purposes of paragraph 160(1)(a) of the Income Tax Act (“ITA”). This decision carries significa...
Oct 17, 2024 6:45:00 AM - Counter Tax Litigators LLP is excited to announce the updated Practical Insight on Penalties under the Income Tax Act (2024), authored by Peter Aprile, James Roberts, and Jennifer Mak, and published b...
Oct 4, 2024 8:15:00 AM - The Federal Court of Canada’s decision in Onex Corporation v. Canada (Attorney General)[1] highlights a meaningful development for taxpayers challenging the Agency’s discretionary decisions. The FC’s ...
Jul 24, 2024 10:15:00 AM - Recent Supreme Court of Canada (SCC) rulings provide critical guidance on tax dispute jurisdiction, shaping how tax reassessments and ministerial decisions should be challenged.
Jan 21, 2024 3:34:00 PM - In Glencore Canada Corporation v. His Majesty the King[1] (“Glencore FCA”), the Federal Court of Appeal examined and ultimately rejected Glencore’s contention regarding the tax treatment of commitment...
Nov 16, 2023 7:43:29 PM - The Tax Court of Canada’s recent ruling in Fiera Foods Company v. HMK1 has significant implications for businesses claiming Input Tax Credits (ITCs) under the Excise Tax Act (ETA).
Sep 7, 2023 5:53:00 PM - Section 111 of the Income Tax Act (“ITA”) allows taxpayers to carry losses back and forward to offset income in different taxation years. However, subsection 111(5) restricts non-capital loss carryove...
May 23, 2023 11:56:52 AM - We’re delighted to announce our newly updated chapter on Corporate Residence & Tax Disputes in Canada (2023), published by Thomson Reuters, is now available.
May 8, 2023 1:27:00 PM - Thompson Reuters considers the authors “leading tax experts and litigators”. The authors agreed to grant TR partial rights to this work. This article first appeared in TR’s Tax Dispute and Resolution ...
Mar 15, 2023 5:25:00 PM - Executive Summary Eastmain believed its CEO’s salary qualified as a “Canadian Exploration and Development Overhead Expenses” and deducted the same. Revenu Québec (“RQ”) denied Eastmain’s 2007 to 2010 ...
Feb 21, 2023 6:14:07 PM - *Thompson Reuters considers the authors “leading tax experts and litigators”. The authors agreed to grant TR partial rights to this work. This article first appeared in TR’s Tax Dispute and Resolution...
Jan 12, 2023 3:12:16 PM - When a CRA auditor thinks the CRA can take a bigger share of your capital, other CRA agents and the CRA’s lawyers will fight to extract it.
Sep 28, 2022 2:14:00 PM - * Thomson Reuters regards the authors as individuals with expertise in tax and litigation. Thomson Reuters has published five Practical Insight chapters on different tax controversy topics, which Coun...
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