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Too much wiggle room in Wigglesworth? Advisor penalties under Income Tax Act not criminal offences in nature and don’t engage protections under s. 11 of the Charter, says Federal Court of Appeal in Guindon

Dentons
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Canada
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June 18 2013

On June 12, 2013, the Federal Court of Appeal released its decision in Canada v. Guindon (2013 FCA 153). The court was tasked with examining the

TCC finds that Pubco had de facto control of R&D company

Thorsteinssons LLP
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Canada
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June 17 2013

In Lyrtech RD Inc. v. The Queen, 2013 TCC 12, the Tax Court of Canada (TCC) held that a public company (Pubco) had de facto control of a Canadian

Making the crime fit the punishment

Thorsteinssons LLP
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Canada
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June 14 2013

The Federal Court of Appeal's recent decision in The Queen v. Guindon attempts to answer the question: when is an intentional action criminal in

Supreme Court rules on the taxation of assumed obligations in asset purchase transactions

Stikeman Elliott LLP
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Canada
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June 12 2013

The Supreme Court of Canada recently released a decision which overturned previous court decisions and confirmed that the assumption of reforestation

Daishowa: characterizing the assumption of obligations when determining the proceeds from disposition

Gowling Lafleur Henderson LLP
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Canada
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June 7 2013

In Daishowa-Marubeni International Ltd. v Canada, 2013 SCC 29, the Supreme Court of Canada ("SCC") held 9:0 that Daishowa-Marubeni International's

Canada Revenue Agency provides update on rulings and GAAR at Toronto centre CRA & professionals group breakfast seminar

Dentons
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Canada
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June 6 2013

On June 6, 2013, at the Toronto Centre CRA & Professionals Breakfast Seminar, the Canada Revenue Agency discussed (a) recent developments at the

Just as intended: 1392644 Ontario Inc. et. Al. V. The Queen

Dentons
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Canada
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June 5 2013

The role of intent in the determination of whether a worker is an employee or independent contractor has taken on greater significance in the last

Supreme Court of Canada rules on value of assumed obligations in asset sales

Norton Rose Canada LLP
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Canada
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June 5 2013

On May 23, 2013, the Supreme Court of Canada (SCC) rendered its decision in Daishowa-Marubeni International Ltd. v Canada in which it concluded that

Class actions, constitutional questions and determining the “preferable proceeding”

McCarthy Tétrault LLP
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Canada
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June 5 2013

In Precision Contractors Ltd v Government of Saskatchewan, 2013 SKCA 57, the Court of Appeal found that a common issue of constitutional validity did

Tax planning, morality and cowboys

Thorsteinssons LLP
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Canada
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June 5 2013

"In quantifying a taxpayer's tax liability under the Income Tax Act is it ever necessary to evaluate the morality of a taxpayer's conduct? As

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Search results

Too much wiggle room in Wigglesworth? Advisor penalties under Income Tax Act not criminal offences in nature and don’t engage protections under s. 11 of the Charter, says Federal Court of Appeal in Guindon

TCC finds that Pubco had de facto control of R&D company

Making the crime fit the punishment

Supreme Court rules on the taxation of assumed obligations in asset purchase transactions

Daishowa: characterizing the assumption of obligations when determining the proceeds from disposition

Canada Revenue Agency provides update on rulings and GAAR at Toronto centre CRA & professionals group breakfast seminar

Just as intended: 1392644 Ontario Inc. et. Al. V. The Queen

Supreme Court of Canada rules on value of assumed obligations in asset sales

Class actions, constitutional questions and determining the “preferable proceeding”

Tax planning, morality and cowboys

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