At Ummat Tax Law, we contribute tax articles and commentary to the greater tax community in a meaningful way by reviewing and analyzing new rules and case law regularly.
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AMIT UMMAT
RECENT TAX ARTICLES
Did this Engineer Have a Permanent Establishment in Canada?
Appellant Fails to Prove Timing of Revenues for Canada/US Treaty Purposes Wolf v. Canada 2019 FCA 283 Access Wolf Decision Here Background This decision raises an interesting treaty-related issue. The Appellant is an aerospace engineer. [...]
Whole Life Insurance Policy Taxable despite Taxpayer’s Belief
Greenstreet v. HMQ 2019 TCC 237 Greenstreet Tax Court Decision Link Decision & Analysis This Tax Court decision involves investment income that the taxpayer did not believe was taxable because the CRA advised him back [...]
TFSA Swap Transactions Considered Tax Avoidance
TFSA Swap Transactions Considered Tax Avoidance Louie v. Canada Decision Louie v. Canada 2019 FCA 255 Background The Appellant, a sophisticated investor, opened a TFSA account when the rules were implemented in January 2009. She [...]
