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Results: 1-10 of 1,794

Tax Court grants huge costs award to taxpayers
  • Thorsteinssons LLP
  • Canada
  • February 13 2014

In a recent decision, Justice Boyle of the TCC awarded a staggering $410,000 cost award to a group of taxpayers who were successful at trial. Boyle J


Supreme Court endorses key tax principle: tax law should follow private law agreements
  • Bennett Jones LLP
  • Canada
  • December 11 2013

The Supreme Court of Canada recently endorsed a fundamental principle in Canadian tax law - namely that absent sham or statutory recharacterization


Brogan Family Trust: CRA not entitled to notice of rectification application
  • Dentons
  • Canada
  • November 13 2014

Is the CRA entitled to notice of a rectification application? In Brogan Family Trust (2014 ONSC 6354), the Ontario Superior Court of Justice said


Gariepy: when is a director’s resignation effective?
  • Dentons
  • Canada
  • September 11 2014

In Gariepy v. the Queen (2014 TCC 254), the Tax Court considered (i) whether two directors had effectively resigned from their positions, and (ii) if


Criminal fraud, tax evasion and the electronic suppression of sales data
  • Thorsteinssons LLP
  • Canada
  • August 13 2013

There can be no doubt that the intentional suppression of sales data, whether through use of an electronic device (often referred to as a "zapper"


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


Pilfold Estate v. The Queen, 2013 TCC 181, Tax Court of Canada (C. Miller J.), 10 June 2013
  • Borden Ladner Gervais LLP
  • Canada
  • August 8 2013

The Tax Court of Canada dismissed an appeal by an Aboriginal taxpayer relating to assessments for the 2000 to 2002 taxation years. There were


The interest deduction: a disturbing judgment.
  • Thorsteinssons LLP
  • Canada
  • March 12 2013

A recent decision of the Tax Court is at times interesting, surprising and disturbing. The case - Swirsky v R, 2013 TCC 73 - raises an important


The McKesson case a holiday gift from Justice Boyle of the Tax Court of Canada: ask and you shall receive(able) Canada’s latest transfer pricing decision
  • Dentons
  • Canada
  • December 31 2013

On Friday, December 20th, the Tax Court of Canada released the long-awaited and lengthy decision of Justice Patrick Boyle in McKesson Canada


Tax Court confirms that the Minister is not above the law
  • Thorsteinssons LLP
  • Canada
  • April 2 2014

The decision in Fio Corporation v. The Queen, 2014 TCC 58 is an interesting and recent example in which the Minister's attempt to gain exemption from