Tax Settlements in Canada: Is it Time to Adopt US Style ADR? Introduction Settlement is about compromise. It’s about grabbing what you can and getting out with a deal you know you can live with. [...]
Minister Was Reasonable to Deny Bonnybrook’s Request for Relief Bonnybrook Park Industrial Development Co Ltd v. Canada (National Revenue) 2022 FC 103 Bonnybrook Decision Link Summary Bonnybrook Park Industrial Development Co Ltd. (“Bonnybrook”) applied for [...]
Choosing The Right Tax Litigation Lawyer In the course of my practice, I am routinely asked the question “what makes you any different from the rest?”. It is an excellent question. And it is certainly [...]
Supreme Court of Canada Dismisses Crown Appeal in Loblaw Financial LOBLAW DECISION Canada v. Loblaw Financial Holdings Inc. 2021 SCC 51 Summary Loblaw Financial Holdings Inc. (“Loblaw”) was reassessed which required it to pay tax [...]
Capital Dividend Account Basics The Capital Dividend Account ("CDA") is part of the Income Tax Act's system of integration (see subsection 89(1) of the Act). Tax integration attempts to ensure that income is subject to [...]
When is the sale of vacant land by an individual subject to HST? The sale of vacant land can be taxable or exempt for purposes of HST under the Excise Tax Act. Generally, vacant land [...]
Director’s Liability Assessment Struck Down by Tax Court of Canada Tran v. Her Majesty the Queen 2021 TCC 51 Tran Decision Here. Summary A corporate director was found not to be liable under the director’s [...]
FCA Finds Appellant in Business of Buying and Selling Homes Wall v. Canada 2021 FCA 132 Wall v. Canada (decision here) Summary A real estate agent and developer disposed of three homes without reporting any [...]
The Saga of Bill C-208 Bill C-208 is a private member's bill that became law on June 29, 2021, and addresses intergenerational transfers of small businesses and farms. Specifically, the Bill amends sections 84.1 and [...]
Former Leafs GM Finally Gets a Win Nonis v. H.M.Q. 2021 TCC 31 DECISION HERE Summary A former Leafs GM was assessed to include income he earned following his termination. The Tax Court of Canada [...]
