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Article

McMillan LLP | Canada | 23 May 2019

Are Courts Curtailing the CRA’s Audit Powers?

In its recent decision in Minister of National Revenue v Cameco Corporation, the Federal Court of Appeal ("FCA") held that the Canada Revenue Agency

Article

Borden Ladner Gervais LLP | Canada | 16 May 2019

Non-residents of Canada not required to disclose books and records to the CRA

The Minister of National Revenue (the Minister) sought an order from the Federal Court to compel three individuals to provide the Canada Revenue

Article

Davies Ward Phillips & Vineberg LLP | Canada | 10 Apr 2019

The CRA Cannot Compel Oral Interviews During an Audit

In Minister of National Revenue v Cameco Corporation, the Federal Court of Appeal (FCA) dismissed the Minister of National Revenue’s appeal and held

Article

Torkin Manes LLP | Canada | 18 Mar 2019

Public Policy Advocacy Activities of Charities: New Developments in 2019

Over the past few months there have been some exciting developments for Canadian registered charities in terms of their ability to engage in advocacy

Article

Borden Ladner Gervais LLP | Canada | 11 Mar 2019

Government Responds to the Report of the Consultation Panel on the Political Activities of Charities

The CRA has developed and published a draft guidance for public consultation to explain how it will administer the new rules on public policy

Article

Fasken | Canada | 7 Jan 2019

Be Careful with Sensitive Tax Information!

The Federal Court’s recent decision in Atlas Tube Canada ULC v MNR1 showcases an important advantage that lawyers bring to multi-disciplinary teams

Article

Borden Ladner Gervais LLP | Canada | 14 Nov 2018

CRA’s Power to Compel Taxpayers to Disclose Uncertain Tax Positions Affirmed

Canada (National Revenue) v Atlas Tube Canada ULC is the latest in a series of cases considering the ability of the Canada Revenue Agency (CRA) to

Article

Stikeman Elliott LLP | Canada | 26 Sep 2018

Alta Energy Luxembourg - Tax Court (Again) Affirms Taxpayer’s Right to Access Treaty Benefits

The Tax Court of Canada has decided in Alta Energy Luxembourg S.A.R.L. v. Her Majesty the Queen that a Luxembourg resident corporation may avail

Article

Torkin Manes LLP | Canada | 21 Sep 2018

Charities and Political Activities Part II

There is more news for Canadian registered charities and the regulation of their political activities. A draft of proposed amendments to the Income

Article

Thorsteinssons LLP | Canada | 24 Aug 2018

Federal Court refuses to authorize abusive “Fishing Expedition” by Canada Revenue Agency

The recent Federal Court decision in Canada (National Revenue) v. Hydro-Québec, 2018 FC 622 made a strong statement against an interpretation of the

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