Management Services, Personal Motives, and the Pursuit of Profit: Brown v. Canada
May 8, 2023 – How the FCA Evolved the Source-of-income Test and Applied Its Decision in Paletta
James represents private companies and high-net-worth individuals in all aspects of tax litigation. He has appeared at the Tax Court of Canada and the Federal Courts.
Some recent highlights in James’ tax litigation practice include the following:
- David Cuddy, Senior Vice-President, Finance & Business Operations, CFL
- Verified Client Feedback for the Legal 500: 2024 Elite Tax Boutique Award
- Laura Couvrette, CPA, CA, Fuller Landau LLP
James started his career at Counter Tax Litigators as a summer student in 2016. Since starting at Counter, James has earned his tax and litigation expertise. Leading tax publications publish his tax dispute insights, and he has helped some of Canada’s top private companies win their tax disputes.
Outside of work, James enjoys spending time with his wife and child. He is also an avid sports fan.
May 8, 2023 – How the FCA Evolved the Source-of-income Test and Applied Its Decision in Paletta
January 21, 2024 - 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...
November 17, 2023 - 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).
September 07, 2023 - 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...
July 05, 2023 - 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...
June 08, 2023 - 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...
May 23, 2023 - We’re delighted to announce our newly updated chapter on Corporate Residence & Tax Disputes in Canada (2023), published by Thomson Reuters, is now available.