Key Takeaways Inconsistent cross-border descriptions created tension between the structure’s design and its economic reality. Risk and benefit flowed to different entities across jurisdictions, shapin...
Key Takeaways CRA’s incentive design produces earlier, larger, and more persistent reassessments. The Large Corporation Rules convert those assertions into temporary capital constraints. For executive...
Key Takeaways Enhanced costs continue to rise. The Tax Court again imposed enhanced costs on the Crown, reinforcing a pattern: disciplined conduct in the right arena creates financial consequences tha...
The following paper provides supporting analysis concerning principles-based conduct guidance within Canada’s tax dispute system and accompanies the present submission respecting conduct principles ac...
Executive Summary Canada’s tax-dispute and litigation system operates without coordinated architecture or design leadership. No institution is responsible for aligning conduct, accountability, and pro...
[Executive Summary Canada’s tax-dispute system lacks a stable way to examine how procedural changes shape the system as a whole. Each institution sees only part of the landscape. As a result, reforms ...
Key Points CRA can now compel sworn questioning. The Income Tax Act authorizes auditors to require oral testimony under oath during audits, bringing executives directly into the record. Early question...
Key Takeaways CRA challenges often evolve from mechanical to interpretive tests. The decisive factor is not a structure’s mechanics but whether its interpretive elements hold up under scrutiny. Meetin...
Chambers Canada 2026 recognized Peter Aprile and Counter Tax Litigators LLP for excellence in tax litigation, reflecting a record of credible outcomes in CRA disputes.
Key Takeaways The Tax Court confirmed that foreign tax interest is not deductible — BMO lost on the law. The result was predictable, but BMO's strategy maximized potential upside while containing the ...