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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…
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…
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…
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…
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The CRA has developed and published a draft guidance for public consultation to explain how it will administer the new rules on public policy…
Fasken | Canada | 7 Jan 2019
Be Careful with Sensitive Tax Information!
The Federal Court’s recent decision in Atlas Tube Canada ULC v MNR[1] showcases an important advantage that lawyers bring to multi-disciplinary teams…
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…
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…
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…
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…
