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RECENT TAX ARTICLES
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”) [...]
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 [...]