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Ontario Court of Appeal unpersuaded by principle that governments have the right to legislate “illogically”

Canada - February 23 2021 In Stonehouse Group Inc. v. Ontario (Minister of Finance), 2021 ONCA 10, a taxpayer was successful in its dispute with the Ministry of Finance. As a…

Morgan Watchorn.

CRA not providing relief where covid-related delays create difficulties in meeting deadline for s. 164(6) loss carrybacks within estate’s first taxation year

Canada - February 18 2021 In CRA Technical Interpretation 2020-0865071E5, the CRA was asked whether it would allow more time for the application of s. 164(6) of the Income Tax…

Morgan Watchorn.

Tax Court of Canada provides clarity on timing of allocating costs between different taxation years

Canada - February 16 2021 In Yorkwest Plumbing Supply Inc. v. The Queen, 2020 TCC 122, due to a switch in the appellant's accounting system the cost of inventory was not…

Morgan Watchorn.

Federal Court of Appeal finds that a corporation must be represented by counsel in tax appeals

Canada - February 12 2021 In Canada v. BCS Group Business Services Inc., 2020 FCA 205, the Federal Court of Appeal held that a corporation cannot not appear “in person” and…

Morgan Watchorn.

Federal Court of Appeal clarifies discontinuance of an appeal not equivalent to a determination of issues under appeal

Canada - October 8 2019 On September 20, 2019, the Federal Court of Appeal (“FCA”) released its decision in Tedesco v. Canada (2019 FCA 325) (“Tedesco”), overturning the…