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”). [...]
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. [...]
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 [...]
The Crown Has the Burden to Prove Gross Negligence Penalties Kim v. Canada Summary In the majority of tax appeals, the taxpayer has the burden of proving the assessments are incorrect. But this case is [...]
FCA Rules Flight Attendant’s Parking Pass a Taxable Benefit Smith Decision Summary The taxpayer received a parking pass from his employer. CRA reassessed to include the value of the parking pass as a benefit pursuant [...]
Value Shifts Remain Subject to the GAAR 2763478 Canada Inc. v. HMQ 2018 FCA 209 Summary The Tax Court upheld an assessment of the Appellant, 2763478 Canada Inc., under the General Anti-Avoidance Rule ("GAAR") to [...]
