Refine your search
785 results found
Miller Thomson LLP | Canada | 14 Mar 2023
When do you need to charge GST/HST on chargebacks?
Many trucking companies have entered into arrangements with subcontracted carriers or owner-operators/contractors for charges such as fuel, insurance…
KPMG Law | Canada | 10 Mar 2023
Federal Court of Appeal comments on source of income test post-Paletta
The Federal Court of Appeal recently provided further guidance on its rephrased source of income test from its recent decision in Paletta. Source of income is a fundamental concept in Canadian tax law. There can be no taxation without income and, subject to specific exceptions, no income without a source.
Thorsteinssons LLP | Canada | 7 Mar 2023
Tax-free savings accounts not always tax-free
In Ahamed v. The King (“Ahamed”), the Tax Court of Canada held that a tax-free savings account (“TFSA”), despite its moniker, is capable of carrying…
Gowling WLG | Canada | 28 Feb 2023
Ten Keys to resolving SR&ED claims
Scientific research and experimental development ("SR&ED") claims can present some of the most complex and challen…
Gowling WLG | Canada | 28 Feb 2023
Five important considerations in settling tax litigation
Settlements are an integral part of a tax litigation practice. Thousands of tax appeals are filed every year with the Tax Court of Cana…
Thorsteinssons LLP | Canada | 22 Feb 2023
Bousfield - Attacking net-worth assessments and other alternative assessment techniques
Bousfield v. The King, 2022 TCC 169, is a recent decision of the Tax Court of Canada that addresses “alternative assessment techniques”. The decision…
Miller Thomson LLP | Canada | 17 Jan 2023
“Checking the Box” not enough to avoid director’s liability for outside director
A decision of the Tax Court of Canada has provided further insight into the duties of an “outside” director who wishes to rely on the due diligence…
Thorsteinssons LLP | Canada | 28 Nov 2022
Khanna - Federal Court of Appeal provides useful guidance on gross-negligence penalties
Khanna v. The Queen, 2022 FCA 84 is an important decision of the Federal Court of Appeal (the “FCA”) on the topic of gross-negligence penalties…
Thorsteinssons LLP | Canada | 22 Nov 2022
Taxing luxury: Canada’s new luxury items tax
Canada’s new tax on luxury cars, aircraft, and boats - levied under the Select Luxury Items Tax Act (the “SLITA”) - came into effect on September 1…
Miller Thomson LLP | Canada | 10 Nov 2022
Is the burden of proof in tax litigation always on the taxpayer?
Burden of proof is a complex subject in Canadian tax litigation and has been heavily debated in recent years. While many mistakenly think the concept…
