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Federal Court of Appeal confirms a specific pleading of sham increases certainty

Canada - October 22 2021 In the recent Canada v. Pomeroy Acquireco Ltd., 2021 FCA 187 decision, the Federal Court of Appeal (FCA) dismissed the Tax Court of Canada’s decision…

Elizabeth Egberts

Federal Court of Appeal rules sham need not be specifically plead

Canada - October 18 2021 In a decision rendered verbally from the Bench by Justice Woods on September 16, 2021, the Federal Court of Appeal (FCA) dismissed the Taxpayers’…

Elizabeth Egberts

The Pandora Papers and tax investigations in Canada

Canada - October 8 2021 The recent release of the “Pandora Papers” marks the third database leak containing confidential banking information regarding alleged off-shore tax…

Greg Rafter

Audit disclosure: Do I have the right to remain silent?

Canada - August 3 2021 In the 2021 Federal Budget, the government proposed the allocation of more than $304 million over the next five years to support audit disclosures…

Jay Dyck, Dana O'Shea

Canada introduces new GST/HST regime for non-resident businesses

Canada - April 29 2021 On July 1, 2021, new rules take effect that significantly broaden the obligations of non-resident businesses to register for and comply with the G…

Bobby B. Solhi, Beverly Gilbert, Joseph (Hovsep) Takhmizdjian, Braek Urquhart