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Taxpayer Beware: Courts May Choose to Ignore a CRA Administrative Concession

Canada - August 14 2017 Taxpayers regularly argue that an administrative policy adopted by the Canada Revenue Agency (the “CRA”) constitutes an incorrect interpretation of

The Tax Court disapproves of taking questions “under advisement” in examinations for discovery

Canada - August 10 2017 In Burlington Resources Finance Company v. The Queen, 2017 TCC 144, Madam Justice D’Auray considered a motion brought by the Crown to compel the

Finance Proposes Substantial Changes to Private Corporation Taxation

Canada - July 20 2017 On July 18, 2017, the Department of Finance released its consultation policy paper on the taxation of private corporations first announced in Budget

TCC applies the GAAR to treat post-takeover steps as a cross-border surplus strip

Canada - July 1 2016 In Univar Holdco Canada ULC v. The Queen, 2016 TCC 159, a UK private equity firm (CVC) acquired all the shares of Univar NV (a Netherlands public

Tax Court agrees with itself that trips to Thailand, Indonesia, Cambodia, Vietnam, Malaysia, Philippines, Burma, Ecuador, Venezuela, Honduras, Mexico, Costa Rica and India qualify for medical expense tax credits.

Canada - June 30 2014 In the recent Tax Court case of Trudy Tallon v. the Queen, Woods, J. was asked to rule on travel and transportation medical expenses tax credits

CBACPA Joint Committee on Taxation - Submissions on Voluntary Disclosure Program

Canada - August 17 2017 Following the CRA’s release of Draft Information Circular IC00-1R6 proposing drastic changes to the Voluntary Disclosure Program, the Joint Committee

Taxpayer Beware: Courts May Choose to Ignore a CRA Administrative Concession

Canada - August 14 2017 Taxpayers regularly argue that an administrative policy adopted by the Canada Revenue Agency (the “CRA”) constitutes an incorrect interpretation of

The Tax Court disapproves of taking questions “under advisement” in examinations for discovery

Canada - August 10 2017 In Burlington Resources Finance Company v. The Queen, 2017 TCC 144, Madam Justice D’Auray considered a motion brought by the Crown to compel the

CRA comments on low-PUC stock dividends and safe income.

Canada - August 1 2017 In 2016-0658351E5 (recently released), the CRA observed that the new rules in s. 55 applicable to low-PUC stock dividends and safe income do not

CRA says lender-consent fees were not subject to withholding tax.

Canada - July 24 2017 In 2016-0636721I7, a Canadian corporation (Canco) paid fees to existing non-resident lenders for their consent to allow the sale of shares of Canco