In cases heard under the TCC’s general procedure (as opposed to the informal procedure), the winning party may receive more than the amount of taxes in dispute plus interest—that is, the court may awa...
We have experience representing SR&ED claimants at the objection and appeal stages. At times, we have questioned the CRA’s level of service and processes surrounding SR&ED objections. Today, the CRA p...
We have written several postings related to the proposed changes in the Tax Court Act and Tax Court Rules. To review, the proposed changes seek to increase the Tax Court Informal Procedure Limits (i.e...
The Canada Revenue Agency Appeals Branch provided our firm with the following statistics related to the number of tax dispute and tax litigation files along with the rates of settlement, withdrawal an...
The Department of Finance (Finance) has released a document entitled Consultation Regarding the Impact of Contingency Fees on the Effectiveness of the Scientific Research & Experimental Development Ta...
Subparagraph 60(o)(i) of the Income Tax Act (ITA) allows a taxpayer to deduct legal fees paid to contest an assessment of tax, interest or penalties including, but not limited to, fees incurred to pro...
In or about 1995, the “detax” or “untax” movement has been moving through Canada. Since that time, detax organizations have been gaining profit holding seminars that spread the detax philosophy. Gener...
It is trite law that the Canada Revenue Agency (CRA) has the authority to impose tax penalties for non-compliance with the Income Tax Act (ITA). The Tax Court of Canada (Tax Court) recently released K...
Tucked in with the promise of prosperity, job creation, and fiscal restraint in the federal government’s recent budget was another commitment: to move forward with changes aimed at improving caseload ...
We have discussed the Department of Finance’s (“Department”) proposed changes to the Tax Court of Canada Act. The Department posits that these changes will improve tax disputes between taxpayers and t...