Tax Dispute Caselaw & Signals

Key Takeaways The appeal failed because the parties continued after the win path had closed. The hearing created no real opportunity or upside. The case continued without a clear stop-point, turning t...

Keybrand Foods Inc. v. HMQ, shows how interest-deductibility disputes, and others like them, are shaped after reassessment as the objection record crystallizes the explanation of the business situatio...

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...

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 ...

Key Takeaways Benefit without cost invites scrutiny: Courts scrutinize tax structures that offer benefit without tradeoff, and when they find this gap, they side with the CRA and uphold the reassessme...

Two decades later, the CRA continues to test the link between borrowing and income in financing structures, often under s. 20(1)(c)(i). The logic in Ludco still governs how those challenges are read. ...

Key Takeaways No inference of intent: Courts rejected the claim that surplus cash was earmarked for decommissioning in the absence of contemporaneous reserves, allocations, or disclosures. Rational co...

Key Takeaways Forum defines outcomes: The taxpayer’s appeal was quashed without the merits ever being heard because the chosen forum lacked jurisdiction. Procedure equals substance: Courts enforce jur...

Key Takeaways Framing gap: The Tax Court accepted CRA’s framing because Vortex’s reply lacked engineering support and legal positioning. In other disputes, when claims were framed with qualified techn...