*Thompson Reuters considers the authors “leading tax experts and litigators”. This content first appeared in TR’s, Practical Insights in May 2020.*
*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, Practical Insights in May...
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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...
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 ...