Air BnB Sale Subject to GST/HST
Overview of Tax Court of Canada’s Ruling in 1351231 Ontario Inc v. The King Air BnB Sale subject to GST/HST DECISION LINKED HERE By: Amit Ummat and Alisha Butani Facts In February 2008, the Appellant, [...]
Overview of Tax Court of Canada’s Ruling in DEML Investments Limited v. The King
Overview of Tax Court of Canada’s Ruling in DEML Investments Limited v. The King 2024 TCC 27 DECISION HERE In DEML Investments Limited v. The King 2024 TCC 27 (the “Case”), Justice Bruce Russell was [...]
Watts Tax Case: Section 160 Applies to Transfer for Home Purchase
[This first appeared in the Canadian Tax Foundation's 2023 Ontario Tax Conference Materials] Watts v. HMK 2023 TCC 11: Section 160 Applies to Transfer for Home Purchase DECISION HERE Summary Miriam Watts (Appellant) received an [...]
Corporate Director Unsuccessfully Relies on the Defence of Due Diligence
Corporate Director Unsuccessfully Relies on the Defence of Due Diligence Burnett Tax Court of Canada Decision Burnett v. HMK 2022 TCC 99 Tax Court of Canada Case Summary This is a typical director’s liability case, [...]
Tax Court of Canada Settlement Conferences
Tax Court of Canada Settlement Conferences The conventional settlement conference is the preferred apparatus most used by parties trying to settle a tax appeal. A settlement conference is a confidential conference where the parties and [...]
CRA Criticized for Questioning Taxpayer’s Business Judgment
CRA Criticized for Questioning Taxpayer’s Business Judgment Jackman v. HMQ 2022 TCC 73 DECISION HERE Summary The Tax Court of Canada (“TCC”) was tasked with determining the value of a shareholder benefit, if any, in [...]
Taxpayer Not Entitled to Deduct Losses on Income Account
Taxpayer Not Entitled to Deduct Losses on Income Account Procon Mining & Tunnelling Ltd. v. HMQ 2022 TCC 71 Decision Here Summary This is a simple case of whether shares owned by a taxpayer were [...]
Tax Settlements in Canada: Is it Time to Adopt US Style ADR?
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
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
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 [...]