Federal Court of Appeal Includes Taxes Payable in Computation of Safe Income Access Decision Here 626468 New Brunswick Inc. v. Her Majesty the Queen 2019 FCA 306 Summary The Federal Court of Appeal (“FCA”) dismissed [...]
Canada v. Alta Energy Luxembourg S.A.R.L. 2020 FCA 43 ACCESS ALTA ENERGY DECISION HERE Summary The Respondent Alta Energy Luxembourg (Alta Luxembourg) argued at the Tax Court of Canada (TCC) that the large taxable capital [...]
Federal Court of Appeal Rules Crown Must Honour Settlement Agreement CBS Decision Here Canada v. CBS Canada Holdings Co. 2020 FCA 4 Summary CBS entered into a settlement with the Crown in respect of the [...]
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”) [...]
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. [...]
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 [...]
TFSA Swap Transactions Considered Tax Avoidance Louie v. Canada Decision Louie v. Canada 2019 FCA 255 Background The Appellant, a sophisticated investor, opened a TFSA account when the rules were implemented in January 2009. She [...]
Innocent Mistake Leads to TFSA Penalty Robitaille v. The Queen (click here for decision) The taxpayer inadvertently deposited $40,000 to his TFSA. The CRA penalized him for it. The Court upheld the penalty. TFSA Over-Contribution [...]
Tax Court finds No Dividend Received Through Income-Splitting Scheme Trower v. HMQ 2019 TCC 77 Trower Decision Summary CRA assessed Ms. Trower to include a taxable dividend in the amount of $58,900 in 2016 because [...]
Taxpayer’s Lack of Credibility Sinks Appeal Wall Tax Court Decision Summary This is a case about a taxpayer lacking credibility and the Tax Court Judge not accepting his evidence as a result. A real estate [...]
