Key Takeaways Legal framing decisive: The CRA’s misinterpretation of treaty and domestic provisions collapsed on appeal, shifting control of the dispute to the taxpayer. Facts aren’t final: Even where...
Guest: Peter Aprile
Guest: Peter Aprile
The Supreme Court of Canada's recent ruling that administrative monetary penalties do not offend constitutional rights will likely have a “chilling” effect on tax advisers, Toronto tax litigation lawy...
Advocate Daily originally published, “Passion, talent not enough to prove business activities”, in July 2015. A recent Tax Court of Canada decision that questioned whether a hockey blog is a business ...
In Tax Court of Canada appeals, the pleadings are the most important documents that the parties file. The Appellant (taxpayer) is required to file a Notice of Appeal, and the Respondent Minister of Na...
The Federal Court of Appeal has recently made it clear that the decision in Canada v. Sommerer [2012] FCA 207 is correct and subsection 75(2) of the Income Tax Act does not apply to property sold for ...
A significant costs award and even-handed analysis provided by the Tax Court of Canada in a recent case will serve to remind the government that tax litigation carries financial consequences, Toronto ...
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...