Insights

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...

Key Takeaways Expert credibility matters: CRA’s independent, balanced expert persuaded the Court, while the taxpayer’s conflicted expert undermined its case. Evidence must stand on its own: Expert rep...

Subsection 169(1) of the Income Tax Act (the “Act”) provides, in part, that a taxpayer may institute an appeal in the Tax Court of Canada to dispute a (re)assessment or notice of confirmation (jointly...

Section 227.1 of the Income Tax Act and section 323 of the Excise Tax Act provide that the CRA can assess corporate directors personally for a corporation’s failure to remit payroll deductions and GST...

In Bozzer v. Her Majesty the Queen (“Bozzer”), Federal Court of Appeal held that the taxpayer relief provisions contained in the Income Tax Act allow the Minister of National Revenue (“Minister”) and ...

The Minister of Finance, the Minister of Justice and the Attorney General of Canada have invited the public to comment on proposed changes to the Tax Court of Canada’s Rules.