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Results: 1-7 of 7

Federal Court of Appeal confirms duty of full disclosure in ex parte production applications

  • Blake Cassels & Graydon LLP
  • -
  • Canada
  • -
  • April 5 2013

In a recent decision of the Federal Court of Appeal (FCA), Canada (National Revenue) v. RBC Life Insurance Company, 2013 FCA 50, the FCA confirmed

Birchcliff Energy: accessing particulars of Crown's position in a GAAR case

  • Blake Cassels & Graydon LLP
  • -
  • Canada
  • -
  • February 20 2013

On December 21, 2012, the Tax Court of Canada released its decision in Birchcliff Energy Ltd. v. The Queen. The decision provides taxpayers with an

Legal trends '13: a forecast of the year ahead - tax controversy & litigation

  • Blake Cassels & Graydon LLP
  • -
  • Canada
  • -
  • January 17 2013

The Canada Revenue Agency (CRA) audits large corporate taxpayers on a regular basis. To improve efficiencies and cash recoveries, the CRA has moved to

Supreme Court of Canada upholds new test for residency of trusts

  • Blake Cassels & Graydon LLP
  • -
  • Canada
  • -
  • April 16 2012

The Supreme Court of Canada (the SCC) released its decision in Fundy Settlement v. Canada (a.k.a. St. Michael Trust Corp. or Garron Family Trust

Velcro Canada case: latest chapter in treaty shopping

  • Blake Cassels & Graydon LLP
  • -
  • Canada
  • -
  • March 5 2012

Under the Canadian Income Tax Act, withholding tax is generally imposed on cross-border payments of dividends, royalties and related-party interest

Need for strategic management of tax controversies

  • Blake Cassels & Graydon LLP
  • -
  • Canada
  • -
  • February 7 2012

In many tax disputes involving large amounts, particularly in the transfer pricing and “aggressive tax planning” areas, formal litigation in the Tax Court (which has exclusive original jurisdiction to hear federal income tax and Goods an Services Tax cases) is becoming acrimonious, much to the displeasure of some judges who have, on occasion, been openly critical of a perceived decline in co-operation between counsel and parties to the proceedings

Some recent jurisprudence

  • Blake Cassels & Graydon LLP
  • -
  • Canada
  • -
  • February 7 2012

On December 16, 2011, the Supreme Court of Canada (SCC) released its decision and reasons in Copthorne Holdings Ltd. v. Canada (Copthorne