Insights

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...

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).

Key Takeaways for Non-Parties Declining involvement is the default, standard, and strategic approach. DoJ and CRA inquiries post-audit do not create a legal obligation to respond. Written communicatio...

Key Points in Glencore The case involves an appeal against a reassessment under the Income Tax Act, where the Minister of National Revenue assessed as income certain fees Falconbridge received due to ...

Management M.-A. Roy Inc. v. HMK (“Gestion Roy”) centers around whether an Opco’s decision to pay insurance premiums, with two Holdcos as the policy owners, gives rise to a shareholder benefit under s...

Counter Tax Litigators LLP has contributed an updated chapter on Corporate Residence Disputes and Strategies, published by Thomson Reuters in its Tax Disputes & Resolution Centre.

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 ...

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 ...

*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...