Alan M. Schwartz

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Canada Life: The Denial of Rescission is a Troubling Decision for Taxpayers and Professional Advisors

Canada - July 12 2018 On June 21, 2018, the Ontario Court of Appeal handed down a decision in the case of Canada Life Insurance Company of Canada v. the Attorney General of…

New Proposals on the Taxation of Private Corporations can result in Double Taxation

Canada - September 13 2017 Much has been written regarding the proposals released by the Department of Finance on July 18, 2017 to limit income splitting and holding passive…

Tax Residency of Trusts in Canada: Application of the Central Management and Control Test Post-Garron

Canada - February 18 2016 Canadian and provincial income taxes are assessed on worldwide income on the basis of a taxpayer's residence. Subsection 104(2) of the Income Tax Act…

Daniel Conrad.

The Supreme Court of Canada rules in favor of taxpayers regarding retroactive rectification of documents and their enforceability against tax authorities

Canada - November 29 2013 On November 28, 2013, in the Services environnementaux AES Inc. case, the Supreme Court of Canada ("SCC") has confirmed a decision of the Qu&eacute…

François Barette, Frédéric Barriault, Kevin H. Yip, L. David Fox, Nikolas Blanchette.

UK Prudential case: accountants’ tax advice not privileged

Canada - March 7 2013 The UK Supreme Court has held in the recent case of R (on the application of Prudential plc and another) v. Special Commissioner of Income Tax and…

Kathleen S.M. Hanly, Thomas Brook.