Précis: The taxpayer corporation invoiced for the legal services of its principal, James Aitchison, a lawyer who owed in excess of $2,000,000 to the Crown in unpaid income taxes. CRA assessed the corporate taxpayer pursuant to subsection 160(1) of the Act on the basis that its principal had transferred in excess of $2,000,000 of assets to it at a time when he was indebted to the Crown for unpaid income taxes. The taxpayer corporation applied for the determination of two points of law under Rule 58 of the Tax Court of Canada (General Procedure) Rules.
Aitchison Professional Corporation v. R. - TCC: No summary hearing on tax debtor’s transfer of right to invoiceREAD MORE »