The Tax Court’s decision in Landbouwbedrijf Backx B.V. v. Canada, 2021 TCC 2 is a reminder to taxpayers that just because their filing position in a tax return is accepted by the Minister of National Revenue (the “Minister”), it…
In Paletta Estate v The Queen, 2021 TCC 11, the Tax Court of Canada allowed the taxpayer’s appeal in respect of “straddle” transactions undertaken in the early-2000s. In doing so, the Court expressly held that commercial activities undertaken solely…
On December 21, 2020, the Federal Court of Appeal (“FCA”) released its decision in Deyab v Canada, 2020 FCA 222 (“Deyab”), partly overturning the decision of the Tax Court of Canada (“TCC”). The FCA’s decision clarified that failing to…
Further to statements in the Fall Economic Statement, the Canada Revenue Agency has announced an administrative policy relating to the ability of employees to deduct home office expenses for the 2020 taxation year. The policy is temporary and made…
We last wrote about the Land Owner Transparency Act (“LOTA”) on May 23, 2019. On November 30, 2020, the BC Ministry of Finance announced that the LOTA registry has now launched.
In the announcement, the Ministry was unambiguous…
In Stonehouse Group Inc. v. Ontario (Minister of Finance), 2021 ONCA 10, a taxpayer was successful in its dispute with the Ministry of Finance. As a result, a refund of the reassessed taxes was paid. The Minister of Finance…
In CRA Technical Interpretation 2020-0865071E5, the CRA was asked whether it would allow more time for the application of s. 164(6) of the Income Tax Act (Canada) where COVID has resulted in delays regarding the administration of an estate. The…
In Yorkwest Plumbing Supply Inc. v. The Queen, 2020 TCC 122, due to a switch in the appellant’s accounting system the cost of inventory was not properly allocated against the cost of sales. The appellant attempted to overstate its…
In Canada v. BCS Group Business Services Inc., 2020 FCA 205, the Federal Court of Appeal held that a corporation cannot not appear “in person” and must be represented by counsel in appeals under the Tax Court’s General Procedure.…
On February 9, 2021, Chief Justice Eugene Rossiter of the Tax Court of Canada held a webinar to update the public on the Court’s current status and outlook as a consequence of the COVID-19 pandemic.
The Tax Court previously announced…
