What is a Notice of Objection?
Notices of Objection in Brief By Amit Ummat LLB LLM CS* *Certified Specialist, Taxation Law This brief article describes the process of filing a notice of objection with the CRA. When a taxpayer is reassessed, [...]
Cirque du Soleil Founder Barred From Deducting Trip to Space
Trip to the International Space Station Found to be Personal Cirque du Soleil Founder Barred From Deducting Trip to Space Laliberté v. Canada 2020 FCA 97 Decision Here Summary This is about as interesting as [...]
Construction Materials Supplier Must Disclose Customer Information to the CRA
Construction Materials Supplier Must Disclose Customer Information Construction Store Ordered to Disclose Customer Information to the CRA Roofmart Ontario Inc. v. Canada (National Revenue) 2020 FCA 85 Roofmart Decision Here Summary This is a critical [...]
Important Director’s Liability Case Decided by Court of Appeal
FCA Allows Director to Challenge Underlying Assessment Duque v. Canada 2020 FCA 73 Access Decision Here Summary Directors Can Challenge Underlying Corporate Tax Assessments This is an important case to be aware of if you [...]
FCA Confirms Broad-Based Audit Powers of the CRA
FCA Confirms Broad-Based Audit Powers of the CRA Canada (Attorney General) v. Valero Energy Inc. 2020 FCA 68 Decision Here Summary The Canada Revenue Agency issued requirements for information while auditing Valero Energy Inc (“Valero”). [...]
Good Advice for Small Business During a Pandemic
Good Advice for Small Business During a Pandemic [This article was originally published by the Lawyers Daily in March 2020] The economic impact relating to the Covid-19 virus will be felt by every corner of [...]
FCA Includes Taxes Payable in Computation of Safe Income
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 [...]
The FCA Refuses to Apply the GAAR in Treaty Benefits Case
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 [...]
Court Forces CRA to Honour Settlement Agreement with Taxpayer
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
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”) [...]