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 [...]
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 [...]
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 – [...]
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 [...]
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 [...]
Repeated Failures to Report Lead to Harsh 163(1) Penalty Polubiec Decision Summary The Appellant was reassessed a 163(1) penalty in 2015 in respect of his 2014 taxation year for failing to report income (RRSP withdrawal). [...]
CRA’s Last Resort: The Dreaded Net Worth Assessment Background Many aspects of the Canada Revenue Agency (“CRA”) and its tax collection measures trouble the average Canadian. But likely the most troublesome -- and controversial -- [...]
Trading in Shares: Income or Capital? Are you earning income or capital gains by your trading activity? A prominent issue encountered by Canadian taxpayers is whether the gains from the sale of shares are income [...]
