Executive Summary A recent ruling by the Federal Court of Appeal in Gestion M.-A. Roy Inc. v Canada, 2024 CAF 16, underscores a growing risk in corporate tax planning: life insurance premiums paid by ...
In Glencore Canada Corporation v. His Majesty the King[1] (“Glencore FCA”), the Federal Court of Appeal examined and ultimately rejected Glencore’s contention regarding the tax treatment of commitment...
Executive Summary CRA’s enforcement activity is increasing, making tax disputes more complex and financially significant. Counter Tax LLP has elected Natalie Worsfold as its Managing Partner, reinforc...
The Tax Court of Canada’s recent ruling in Fiera Foods Company v. HMK1 has significant implications for businesses claiming Input Tax Credits (ITCs) under the Excise Tax Act (ETA).
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...
Key Takeaways for Non-Parties Declining involvement is the default, standard, and strategic approach. DoJ and CRA inquiries post-audit do not create a legal obligation to respond. Written communicatio...
Key Points in Glencore The case involves an appeal against a reassessment under the Income Tax Act, where the Minister of National Revenue assessed as income certain fees Falconbridge received due to ...
Counter Tax Litigators LLP has contributed an updated Practical Insight on Judicial Review under the Income Tax Act, authored by Peter Aprile and James Roberts and published by Thomson Reuters in its ...
Management M.-A. Roy Inc. v. HMK (“Gestion Roy”) centers around whether an Opco’s decision to pay insurance premiums, with two Holdcos as the policy owners, gives rise to a shareholder benefit under s...
Counter Tax Litigators LLP has contributed an updated chapter on Corporate Residence Disputes and Strategies, published by Thomson Reuters in its Tax Disputes & Resolution Centre.