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 [...]
CRA Voluntary Disclosure Program Reviewed 4053893 Canada Inc. v. Canada (National Revenue) 2021 FC 218 DECISION HERE Tax Case Summary 4053893 Canada Inc. (“405”) applied for a second judicial review of the Minister’s decision to [...]
Tax Court of Canada Rules Straddle Transactions Not a Sham Paletta Estate v. H.M.Q. 2021 TCC 11 DECISION HERE Summary The appellant[1] entered into straddle transactions to shelter income. The Minister of National Revenue (“Minister”) [...]
FCA Allows Appeal Against a Section 160 Assessment Eyeball Networks Inc. v. Canada 2021 FCA 17 DECISION HERE Summary The Tax Court of Canada (“TCC”) dismissed the Appellant’s appeal against a subsection 160(1) assessment. The [...]
Tax Court Rules on Employee Benefit Plans McNeeley v. The Queen 2020 TCC 90 https://decision.tcc-cci.gc.ca/tcc-cci/decisions/en/item/486041/index.do?q=mcneeley Summary The three Appellants appealed their 2012 reassessments indicating the Minister of National Revenue’s (“Minister”) position that they had received [...]
Corporations Must be Represented by a Lawyer in Tax Court of Canada Canada v. BCS Group Business Services Inc. 2020 FCA 205 Summary The Crown successfully appealed a Tax Court of Canada (“TCC”) decision allowing [...]
Minister’s Refusal to Grant Remission Unreasonable Mokrycke v. Canada (Attorney General) 2020 FC 1027 Summary The Applicant applied for a remission order, which was rejected by the Minister of National Revenue (“Minister”). The Applicant sought [...]
Agracity Ltd. v. HMQ 2020 TCC 91 Summary The Tax Court of Canada (“TCC”) allowed the appeals relating to transfer pricing assessments on the basis that there was no sham and that there was [...]
Supreme Court of Canada Rules on Losses Stemming from Derivative Contract MacDonald v. Canada 2020 SCC 6 Summary This appeal dealt with what are known as derivative contracts and whether gains and losses from those [...]
GAAR DOES NOT APPLY TO SOPHISTICATED TAX PLAN INVOLVING LOSS-STREAMING MMV Capital Partners Inc. v. The Queen 2020 TCC 82 Decision Here Summary The Tax Court of Canada found that the GAAR did not apply [...]
