The Tax Court of Canada has ruled the allowable limits provision of the TCC tariff is not definitive and judges have the discretion to exceed amounts set out in it.
A recent Tax Court of Canada decision will hopefully persuade the Minister of National Revenue to reconsider the routine imposition of harsh penalties for failing to report income, Toronto tax litigat...
In a potentially precedent-setting case, the Tax Court of Canada has determined that the often “harsh” penalties imposed on taxpayers who misreport income in two out of four years cannot be imposed if...
Tax disputes with the Canada Revenue Agency (CRA) present a complex challenge for individuals and businesses alike. Understanding the interplay between audit, objection, appeals, and collections proce...
The Tax Court of Canada in October last year released its reasons for judgment in Brent Kern Family Trust v. Canada [2013] T.C.J. No. 286. The case was the TCC’s first opportunity to review and apply ...
Advocate Daily initially originally published, "Tax court should go further when awarding costs”, in March 2014. Although a recent Tax Court of Canada decision shows a continued trend towards higher c...
The Income Tax Act (“ITA”) provides various tax advantages to corporations that qualify as Canadian-Controlled Private Corporations (“CCPC”).
Late last year, the Tax Court of Canada released its reasons for judgment in Ironside v. Canada [2013] T.C.J. No. 298, and Gouveia v. Canada [2013] T.C.J. No. 353. In Ironside and Gouveia, the Tax Cou...
The Canada Revenue Agency (“CRA”) announced, and now initiated, its 5th Annual Letter Campaign (the “Campaign”).** The CRA is in the process of sending 33,000 letters to taxpayers that have claimed bu...
Advocate Daily originally published “New CRA tools may mean more tax haven proceedings” in December 2013. Although the Canada Revenue Agency has reportedly struggled to deal with the number of cases i...