Federal Court of Appeal: Advisor Penalties Under Section 163.2 of the Income Tax Act Are Not Criminal Offences and Do Not Attract the Protection of Section 11 of the CharterREAD MORE »
Anonby v. The Queen: Tax Court Does Not Have Jurisdiction Over Source Deductions or to Increase Tax PayableREAD MORE »
Lehigh Cement Limited v. The Queen – Common sense advocacy brings the taxpayer success in an anti-avoidance case involving a foreign affiliate.READ MORE »
Boardwalk Equities Inc. V. The Queen – Federal Court of Appeal holds GST payable on the full cost of natural gas and electricity notwithstanding that part of that cost was paid directly to the suppliers by the province of AlbertaREAD MORE »
Large Corporations and the Fine Line between “Issues” and “Reasons” – Canadian Imperial Bank of Commerce v. The QueenREAD MORE »
Ficek v. R. – FCt: CRA Intentionally Delayed Processing Returns to Avoid Issuing Refunds to Tax Shelter InvestorsREAD MORE »
Daishowa Marubeni International Ltd. v. Canada – Supreme Court of Canada Endorses “Symmetry and Fairness” in the Interpretation of Taxation StatutesREAD MORE »
Myrdan Investments Inc. v. The Queen – Taxpayers Awarded One Third of Their Out of Pocket Costs (154% of the Tarriff) Because of CRA’s IntransigenceREAD MORE »