Canada - September 23 2019
Context: In 1982 the CRA published its position on barter transactions, describing them as transactions “effected when any two persons agree to a…
Canada - October 23 2017
Section 16 of the Income Tax Act (Canada) provides that "Where, under a contract or other arrangement, an amount can reasonably be regarded as being…
Canada - October 16 2017
Canada's general anti-avoidance rule (the GAAR) in s. 245 of the Income Tax Act is, in the final analysis, an anti-abuse rule. Even if a transaction…
Canada - October 11 2017
Consider a case in which a foreign resource business is carried on through a limited partnership, and the partnership disposes of a foreign resource…
Canada - October 3 2017
In The Queen v. Repsol Canada Ltd. et. al., 2017 FCA 193, the Federal Court of Appeal (FCA) upheld the Tax Court of Canada's decision to include in…
