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 [...]
What is Involved in a Tax Appeal? Steps in a Tax Court Appeal At Ummat Tax Law, we receive many calls from taxpayers who are simply unaware of what an appeal to Tax Court entails. [...]
Tax Court Practice Note on Expert Evidence One of the noblest aspects of practicing tax litigation is the privilege of appearing before the venerable Tax Court. The judges are brilliant, the registrar's office and the [...]
Tax Court Decision on Experts at Trial Canadian Imperial Bank of Commerce v. H.M.Q. 2018 TCC 248 Summary This recent decision addresses a party's ability to have more than the five permitted experts testify at [...]
Tax Court Rules in Favour of Minister Pangaea One Acquisition Holdings XII S.À.R.L. v. The Queen 2018 TCC 158 Summary: In this Tax Court decision, the Appellant ("Pangaea") argued that it should be entitled to [...]
