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Results: 1-10 of 1,885

Tax Court allows credit for portion of inflated donation receipts
  • Thorsteinssons LLP
  • Canada
  • January 20 2015

In David v. Canada (2014 TCC 117), the Tax Court of Canada allowed six appeals concerning the disallowance of charitable donation tax credits on


CRA describes interpretation of s.95(6)(b) post Lehigh
  • Thorsteinssons LLP
  • Canada
  • January 20 2015

In 2014-0550441C6, the Canada Revenue Agency set out how the Federal Court of Appeal’s decision in the Lehigh Cement case affects the CRA’s


Rectification is about intention not interpretation
  • Bennett Jones LLP
  • Canada
  • January 20 2015

The Ontario Superior Court of Justice recently granted rectification in a case in which the CRA and the taxpayer differed in their interpretation and


Tax Court rules deportee "not ordinarily resident" for child tax benefit
  • Karas Immigration Law Professional Corporation
  • Canada
  • December 9 2014

A very interesting case: the Tax Court ruled that a person who was deported from Canada was not "ordinarily resident" for the purpose of receiving


Osler’s insights on key developments in 2014 and their implications for Canadian business.
  • Osler Hoskin & Harcourt LLP
  • Canada
  • December 9 2014

Four securities regulatory developments in 2014 warrant special attention:The Canadian Securities Administrators (CSA) proposed a new “permitted bid”


Secured creditors can appeal to Tax Court on behalf of a bankrupt
  • Bennett Jones LLP
  • Canada
  • December 2 2014

The Tax Court of Canada recently confirmed in International Hi-Tech Industries Inc v The Queen, 2014 TCC 198, that in certain circumstances a secured


Legge: improper pleading fatal to Crown’s case
  • Dentons
  • Canada
  • December 9 2014

What must the Crown plead and how must she plead it? This question became an issue in the Tax Court's recent decision in Legge v. The Queen (2014 TCC


Superior Court allows rectification of resolutions to avoid FX gain
  • Thorsteinssons LLP
  • Canada
  • January 5 2015

In Fairmont Hotels Inc. et al v. A.G. Canada, 2014 ONSC 7302, the Superior Court of Ontario exercised its discretion to allow Canadian companies in a


Tax Court finds RRSP trustee liable for withholding tax on share purchase
  • Thorsteinssons LLP
  • Canada
  • January 5 2015

Where a non-resident of Canada sells taxable Canadian property (TCP), the purchaser of such property can be liable for withholding tax under s. 116


Ontario Court of Appeal upholds tax-efficient internal financing
  • Thorsteinssons LLP
  • Canada
  • August 13 2014

In Inter-Leasing, Inc. v. Ontario (Revenue), 2014 ONCA 575, rev'g 2013 ONSC 2927, the Ontario Court of Appeal (OCA) upheld an internal group