When the CRA has made an assessment of tax and the taxpayer has started an appeal in the Tax Court, the taxpayer and the CRA can agree to settle the appeal without proceeding with an actual trial in court. This…
Many tax planning transactions fall within the definition of “avoidance transaction” in subsection 245(3) of the Income Tax Act and as such are subject to review under the general anti-avoidance rule (GAAR). Equally, many of the transactions that are reviewed…
The following article, written by James Murdoch, was first published by STEP Canada in the May 2012 edition of STEP INSIDE, the quarterly publication of the Society of Trust and Estate Practitioners (Canada):
On April 12, 2012 the Supreme Court…
A wise man once said that when your boat has capsized in a pond full of alligators, it’s hard to remember that the reason you’re there in the first place is to drain the swamp. A recent letter to the…