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 [...]
Supreme Court of Canada Grants Leave to Appeal in Treaty Shopping Case Her Majesty the Queen v. Alta Energy Luxembourg SARL case no: 39113 Case 39113 Summary The Respondent Alta Energy Luxembourg (Alta Luxembourg) argued [...]
CanLII Entitled to $745,690 of Input Tax Credits Canadian Legal Information Institute v. The Queen 2020 TCC 56 CANLII Decision Here Summary The Canadian Legal Information Institute (CanLII) claimed ITC’s for its April 2013 – [...]
Federal Court of Appeal Clarifies Onus of Proof in Tax Cases Eisbrenner Decision Here Eisbrenner v. Canada 2020 FCA 93 Summary This case involved charitable donations where the value of the receipts greatly exceeded the [...]
