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FCA clarifies application of Section 174
  • Thorsteinssons LLP
  • Canada
  • February 26 2014

In Canada v. ACI Properties Ltd., 2014 FCA 45, the Federal Court of Appeal clarified the application of section 174 of the Income Tax Act (Canada

Bill C-31's Serious Offences Amendment to section 241 of the Income Tax Act
  • Gowling WLG
  • Canada
  • June 18 2014

Taxpayers have cause for concern over proposed amendments to the Income Tax Act. Buried in a recent 375-page omnibus bill, Bill C-31, is a provision

Requirements for ITC and ITR claims: A judgment of the Court of Québec sets the record straight
  • Lavery de Billy LLP
  • Canada
  • December 16 2013

In the past few years, the Agence du revenu du Québec ("ARQ") has acted aggressively towards any taxpayers whom it suspects of being involved

CRA owes a duty of care to taxpayers
  • Bennett Jones LLP
  • Canada
  • July 14 2014

While taxpayers have initiated a number of civil claims against the CRA, alleging everything from negligence to fraud, these claims are rarely

Health quest: appeal allowed where Crown failed to properly plead assumptions
  • Dentons
  • Canada
  • July 9 2014

What is the result of the Crown's failure to properly plead its assumptions in the Reply? This issue was considered by the Tax Court in Health Quest

Judicial review, redux
  • Thorsteinssons LLP
  • Canada
  • December 3 2013

It has been just over a month since the Federal Court of Appeal rendered its decision in JP Morgan Canada Asset Management v. AG Canada. In the

Top technical bill issues for owner-managers
  • Miller Thomson LLP
  • Canada
  • December 2 2013

The Department of Finance released a prolific amount of proposed legislation in the last quarter of 2012 and the first quarter of 2013. More

Internet sales tax update
  • Field Law
  • Canada, USA
  • December 6 2013

We recently reported on a case out of New York State, which dealt with the question of sales tax liability in the case of online sales. That decision

Alberta Court of Queen’s Bench confirms rectification cannot remedy unanticipated tax consequences
  • Bennett Jones LLP
  • Canada
  • March 28 2014

The recent decision of the Court of Queen's Bench of Alberta in Graymar Equipment (2008) Inc v Canada (Attorney General), 2014 ABQB 154 is an

Paul Kvas v. The Queen, 2016 DTC 1169
  • Borden Ladner Gervais LLP
  • Canada
  • October 24 2016

The appellants were brothers who had incorporated a company (the “Corporation”) which was, in January 2008, involuntarily dissolved for failure