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No tax deduction for employee stock surrender payments
  • Borden Ladner Gervais LLP
  • Canada
  • August 31 2012

The Supreme Court of Canada has dismissed an application for leave to appeal in Imperial Tobacco Canada Limited v The Queen

UK Prudential case: accountants’ tax advice not privileged
  • Fasken Martineau DuMoulin LLP
  • Canada
  • March 7 2013

The UK Supreme Court has held in the recent case of R (on the application of Prudential plc and another) v. Special Commissioner of Income Tax and

Get it right the first time: Newfoundland Transshipment Ltd. v. The Queen
  • Dentons
  • Canada
  • August 29 2013

In Newfoundland Transshipment Ltd. v. Queen (2013 TCC 259), the Tax Court of Canada dismissed an application by Newfoundland Transshipment ("NTL"

A primer on solicitor-client privilege and third-party disclosure
  • Baker & McKenzie
  • Canada
  • September 23 2013

Solicitor-client privilege is recognized as a fundamental civil right integral to the Canadian legal system.1 Although not absolute, the privilege is

Bakorp: appeal dismissed for failure to comply with large corporations rules
  • Dentons
  • Canada
  • May 6 2014

In Bakorp Management Ltd. v. The Queen (2014 FCA 104), the Federal Court of Appeal upheld a decision of the Tax Court dismissing the taxpayer's

Grounded: cross-border proceeding against Air Canada stayed on basis of forum non conveniens
  • Osler Hoskin & Harcourt LLP
  • Canada, USA
  • May 6 2014

Ontario courts often consider whether they should take jurisdiction over a class action with foreign elements. In its most recent decision - Prince v

Cross Canada legal panel - legal update and British Columbia perspective on equity
  • Lawson Lundell LLP
  • Canada
  • October 2 2012

The Supreme Court of Canada released the much-anticipated decision in Catalyst Paper Corp. v. North Cowicham (District), 2012 SCC on January 20, 2012

Case law update
  • Landwell
  • Canada
  • February 14 2012

The Supreme Court of Canada (SCC) released its decision in Copthorne Holdings Ltd

Morguard Corporation v. The Queen when will a “break fee” be considered income?
  • Dentons
  • Canada
  • March 5 2012

In Morguard Corporation v. The Queen, 2012 TCC 55, Justice Boyle of the Tax Court of Canada considered whether a “break fee” received by a predecessor of the Appellant (for the purposes of this discussion, the “Appellant”) in respect of its unsuccessful attempted acquisition of a public corporation, was received on account of income or capital (there was also a procedural issue that will not be discussed in this post

Further thoughts on the Fundy Settlement decision: Supreme Court offers a nuanced view of trust residence
  • Dentons
  • Canada
  • April 12 2012

In Garron Family Trust v. The Queen (2009 TCC 450), Justice Judith Woods of the Tax Court of Canada came down with a very broad new rule for determining the residence of trusts