Steps in a Tax Court Appeal
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. [...]
The Tax Court of Canada Releases Practice Note on Expert Hot-Tubbing
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 of Canada Decides Five Experts Sufficient for Trial
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 [...]
What is a Restrictive Covenant for Tax Purposes?
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 [...]
Tax Court Finds Appellant a Resident of Canada Based on Central Management and Control
Taxpayer a Resident of Canada or Netherlands? Landbouwbedrijf Backx B.V. v. The Queen 2018 TCC 142 Summary: In this Tax Court decision, Justice Smith was asked to determine the residency of the Appellant, a company [...]
Lawyers’ Insurance Company not a Tax-Exempt Entity
What Factors Lead to Exemption From Tax? Lawyers' Professional Indemnity Company v. H.M.Q. 2018 TCC 194 ("LPIC") LPIC is a relatively straight-forward Tax Court decision penned by Justice D'Arcy. LPIC is a wholly-owned subsidiary of [...]