Précis: In 2016 Associate Chief Justice Lamarre of the Tax Court of Canada (2016 TCC 173) allowed the taxpayer’s appeal from reassessments including in its income for 2005 and 2006, pursuant to section 94.1 of the Act, income from offshore funds in which it had invested. The Crown appealed to the Federal Court of Appeal which dismissed its appeal from the Bench with costs.
R. v. Gerbro Holdings Company - FCA: CRA’s appeal dismissed from the bench – Income from offshore funds not attributable under section 94.1 of the Income Tax Act (the Act)READ MORE »