In White v The Queen[1], the Tax Court allowed Mrs. White’s appeal, holding that the deposits of funds by Mr. White, a “tax debtor”, into a joint bank account held by him and Mrs. White (the “Joint Bank…
In Scott v The Queen, 2020 TCC 4, the Tax Court of Canada held that a transferee’s liability in a section 160 assessment was reduced where, after the assessment, the Minister of National Revenue (the “Minister”) cancelled a portion…
The FAD Rules
Referred to as the foreign affiliate dumping (“FAD”) rules, section 212.3 was designed to restrict a non-resident corporation (a “parent”) from using a corporation resident in Canada (a “CRIC”) as an intermediary to invest in a…
In Canada v Rio Tinto Alcan[1], the Federal Court of Appeal (“FCA”) upheld the Tax Court of Canada (“TCC”) decision[2] confirming, inter alia, the deductibility of certain takeover expenses incurred by Rio Tinto Alcan Inc. (“Alcan”)…
On September 20, 2019, the Federal Court of Appeal (“FCA”) released its decision in Tedesco v. Canada (2019 FCA 325) (“Tedesco”), overturning the decision at the TCC of Canada (“TCC”) (heard as Stewart v. The Queen, 2018 TCC 75). The…
On February 11, 2020, the CRA published a list of tax tips aimed at providing students and taxpayers with no or almost no income with useful reminders on benefits and credits they may qualify for.
In Univar Holdco Canada ULC v The Queen, 2020 TCC 15, the Tax Court awarded costs of over $300,000 in favour of the taxpayer, representing approximately 50% of the taxpayer’s legal fees for the appeal, plus disbursements. In light of…
In reaching the decision, the Tax Court of Canada considered whether the parties to the transaction attempted to place the CRA in “any different position whatsoever as a result of the transfer”. The Court found that they did not.…
Registered owners of residential property in Vancouver are reminded to complete their 2019 property status declarations by February 4, 2020. Owners should have already received reminder notices from the City of Vancouver. Failure to make the declaration will result in…
