Key Takeaways Forum defines outcomes: The taxpayer’s appeal was quashed without the merits ever being heard because the chosen forum lacked jurisdiction. Procedure equals substance: Courts enforce jur...
Key Takeaways Framing gap: The Tax Court accepted CRA’s framing because Vortex’s reply lacked engineering support and legal positioning. In other disputes, when claims were framed with qualified techn...
Key Takeaways Premium payments as benefits: When one company pays premiums on a policy owned by another, courts treat it as a taxable benefit — intent does not override structure. Expanding reach of s...
When CRA issues a Notice of Reassessment (NoR), taxpayers who contest it face a structural choice: remain in CRA’s self-adjudication stage at objection, or transition to the Tax Court’s independent ov...
Cryptocurrencies have redefined wealth creation but also bring unprecedented challenges for tax planning and compliance. As cryptocurrency values soar and governments worldwide heighten scrutiny, Cana...
Executive Summary: The Tax Court drew a hard line: choosing non-CCPC status before a sale is not abuse, at least until Parliament closed the door in 2022.
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...
Resolving Tax Disputes (3rd edition) studies tax disputes, conflict levels, and basic strategies. It helps accountants to limit early-stage mistakes and reduce liability. One of the chapters in RTD3 i...
Resolving Tax Disputes (3rd edition) studies tax disputes, conflict levels, and basic strategies. It helps accountants to limit early-stage mistakes and reduce liability. One of the chapters in RTD3 i...
Resolving Tax Disputes (3rd edition) studies tax disputes, conflict levels, and basic strategies. It helps accountants to limit early-stage mistakes and reduce liability. One of the chapters in RTD3 i...