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RECENT TAX ARTICLES
The FCA Refuses to Apply the GAAR in Treaty Benefits Case
Canada v. Alta Energy Luxembourg S.A.R.L. 2020 FCA 43 ACCESS ALTA ENERGY DECISION HERE Summary The Respondent Alta Energy Luxembourg (Alta Luxembourg) argued at the Tax Court of Canada (TCC) that the large taxable capital [...]
Court Forces CRA to Honour Settlement Agreement with Taxpayer
Federal Court of Appeal Rules Crown Must Honour Settlement Agreement CBS Decision Here Canada v. CBS Canada Holdings Co. 2020 FCA 4 Summary CBS entered into a settlement with the Crown in respect of the [...]
Dutch Company a Canadian Resident for Tax Purposes
Dutch Company a Canadian Resident for Tax Purposes Decision Here Landbouwbedrijf Backx B.V. v. The Queen 2019 FCA 310 Summary In this Federal Court of Appeal (“FCA”) decision, the Court reviewed the Tax Court’s (“TCC”) [...]
