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RECENT TAX ARTICLES
FCA Includes Taxes Payable in Computation of Safe Income
Federal Court of Appeal Includes Taxes Payable in Computation of Safe Income Access Decision Here 626468 New Brunswick Inc. v. Her Majesty the Queen 2019 FCA 306 Summary The Federal Court of Appeal (“FCA”) dismissed [...]
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 [...]