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Conrad Black: resident here, resident there, resident everywhere?
  • Gowling WLG
  • Canada
  • March 20 2014

It is common for an individual to be resident in more than one country at a given time (i.e., to be a "dual resident"). Where an individual is

Supreme Court of Canada denies leave on Aboriginal claim for breach of fiduciary duty
  • Fasken Martineau DuMoulin LLP
  • Canada
  • January 30 2013

On January 17, 2013, the Supreme Court of Canada denied the Blood Tribe's application for leave to appeal the Alberta Court of Appeal's decision in

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

The assumption of rehabilitation liabilities as consideration given on the acquisition of mining property and capital assets
  • ENSafrica
  • Canada, South Africa
  • October 22 2014

During December 2013, SARS released a draft discussion paper in which it set out its application of the relevant tax law, in relation to the tax

A Potential New Standard of Review in Municipal Tax Assessment Appeals
  • MLT Aikins LLP
  • Canada
  • November 16 2016

The Supreme Court of Canada recently came out with a decision in which it decided that reasonableness was the appropriate standard of review on a

Minister of National Revenue commences tax proceedings against generic drug manufacturers
  • Norton Rose Fulbright LLP
  • Canada
  • October 31 2014

On October 23, 2014, the Minister of National Revenue (the Minister) filed Notices of Application in the Federal Court against a number of generic

Deference for Assessment Review Boards
  • Bennett Jones LLP
  • Canada
  • November 8 2016

The standard of review of a composite assessment review board's decision to

Rectification: current developments regarding this useful judicial remedy
  • Miller Thomson LLP
  • Canada
  • July 31 2014

Rectification is an equitable remedy that allows for judicial corrections of a document that, due to errors in drafting, does not reflect the true

“Half-loaf” gone wrong: Gervais, G. et al. v. The Queen (“Gervais”).
  • Miller Thomson LLP
  • Canada
  • July 31 2014

A recent case from the Tax Court of Canada ruled against a taxpayer who implemented a tax plan known as the "half-loaf" plan. The purpose of a

The Latest Word on Subsequent Legislative History and the GAAR
  • Bennett Jones LLP
  • Canada
  • November 1 2016

Two recent decisions of the Tax Court involving the general anti-avoidance rule (GAAR), Univar Holdco Canada ULC v The Queen, 2016 TCC 159 Univar