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 [...]
Avoiding a CRA Audit By Amit Ummat, Ummat Tax Law PC We have many clients who are self-employed. We also represent professionals and businesses who are required to keep their own books and a variety [...]
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 [...]
