Précis: Subsection 145(4) of the Tax Court of Canada Rules (General Procedure) provides that a party cannot call more than 5 expert witnesses at a hearing without leave of the Court. CIBC moved for leave to call 7 expert witnesses in a complex transfer pricing case involving a deduction in the range of $3 billion. The Court rejected CIBC’s application and ordered CIBC to advise the Crown which 5 out of its 7 experts it proposed to call at trial within 7 days of the decision on the application.
Canadian Imperial Bank of Commerce v. R. – TCC: Taxpayer limited to calling 5 of its 7 proposed expert witnessesREAD MORE »