Federal Court Finds Minister’s CRB Decision Unreasonable Moncada Decision Linked here Moncada v. Canada (Attorney General) 2023 FC 114 Summary The Canada Recovery Benefit (“CRB”) provided direct financial support to eligible people residing in Canada [...]
US Supreme Court Will Decide a Case on Solicitor/Client Privilege in a Tax Context Summary The U.S. Supreme Court (“Scotus”) heard oral arguments on January 9, 2023 in a tax case about the scope of [...]
Taxpayer’s Management Services Not a Personal Endeavour Brown v. Canada 2022 FCA 200 Summary The Appellant Mr. Darrell Brown (“Mr. Brown”) appealed his reassessments to the Tax Court of Canada (“TCC”) and lost. He appealed [...]
Tax Reporting Headache - Reportable & Notifiable Transactions Lawyers can usually assist with implementing tax-driven reorganizations cooked up by tax accountants without having to worry about the related tax reporting. A lawyer who prepares a [...]
Bare Trust Reporting Requirements The Department of Finance announced additional reporting requirements in the 2018 Federal Budget, requiring some trusts to provide additional information on an annual basis as part of their tax filings. In [...]
Corporate Director Unsuccessfully Relies on the Defence of Due Diligence Burnett Tax Court of Canada Decision Burnett v. HMK 2022 TCC 99 Tax Court of Canada Case Summary This is a typical director’s liability case, [...]
Tax Court of Canada Settlement Conferences The conventional settlement conference is the preferred apparatus most used by parties trying to settle a tax appeal. A settlement conference is a confidential conference where the parties and [...]
CRA Criticized for Questioning Taxpayer’s Business Judgment Jackman v. HMQ 2022 TCC 73 DECISION HERE Summary The Tax Court of Canada (“TCC”) was tasked with determining the value of a shareholder benefit, if any, in [...]
Taxpayer Not Entitled to Deduct Losses on Income Account Procon Mining & Tunnelling Ltd. v. HMQ 2022 TCC 71 Decision Here Summary This is a simple case of whether shares owned by a taxpayer were [...]
Treaty Calculation Allows Minister to Use any Twelve-Month Period Triskelion Projects International Inc. v. The Queen 2022 TCC 63 DECISION HERE Summary The Appellant tried a clever argument for which no factual basis existed. The [...]
