CRA’s Objection Process: Full Engagement vs. Strategic Disengagement
Key Considerations for Choosing the Most Effective Process
Jennifer Mak
Associate, Tax Litigation
Jennifer resolves tax controversies with a holistic view to deliver the best overall result.
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Insights
July 17, 2024 - Counter Tax Litigators LLP is excited to announce the updated Practical Insight on Penalties under the Income Tax Act (2024), authored by Peter Aprile, James Roberts, and Jennifer Mak, and published...
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...