Key Takeaways Subsection 165(1.11) of the Income Tax Act requires a large corporation to specify in its Notice of Objection the issues, relevant facts, and relief sought. Bakorp Management Ltd. framed...
Key Challenge: Clarifying GST/HST Supply Classification Integrated Transactions: Tax professionals should proactively evaluate whether elements of a purchase are truly independent or part of a single ...
Key Takeaways from Azmayesh-Fard v HMK Enforcement is accelerating. CRA’s access to global financial data has fundamentally changed how offshore holdings are detected. Risk is dynamic. Proactive tax d...
The Federal Court of Appeal’s (“FCA”) decision in Enns v. Canada[1] clarifies how “spouse” is defined for purposes of paragraph 160(1)(a) of the Income Tax Act (“ITA”). This decision carries significa...
Coopers Park (2024 TCC 122) shows CRA intensifying its push to access accountant communications in tax disputes. The risk rises when legal and accounting teams blend, and it remains invisible until th...
The Federal Court of Canada’s decision in Onex Corporation v. Canada (Attorney General)[1] highlights a meaningful development for taxpayers challenging the Agency’s discretionary decisions. The FC’s ...
Recent Supreme Court of Canada (SCC) rulings provide critical guidance on tax dispute jurisdiction, shaping how tax reassessments and ministerial decisions should be challenged.
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...
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).
When a CRA auditor thinks the CRA can take a bigger share of your capital, other CRA agents and the CRA’s lawyers will fight to extract it.
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