Tax Settlements in Canada: Is it Time to Adopt US Style ADR? Introduction Settlement is about compromise. It’s about grabbing what you can and getting out with a deal you know you can live with. [...]
Choosing The Right Tax Litigation Lawyer In the course of my practice, I am routinely asked the question “what makes you any different from the rest?”. It is an excellent question. And it is certainly [...]
Director’s Liability Assessment Struck Down by Tax Court of Canada Tran v. Her Majesty the Queen 2021 TCC 51 Tran Decision Here. Summary A corporate director was found not to be liable under the director’s [...]
Former Leafs GM Finally Gets a Win Nonis v. H.M.Q. 2021 TCC 31 DECISION HERE Summary A former Leafs GM was assessed to include income he earned following his termination. The Tax Court of Canada [...]
Tax Court of Canada Rules Straddle Transactions Not a Sham Paletta Estate v. H.M.Q. 2021 TCC 11 DECISION HERE Summary The appellant[1] entered into straddle transactions to shelter income. The Minister of National Revenue (“Minister”) [...]
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 [...]
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 [...]
