On March 25, 2021, the Supreme Court of Canada (“SCC”) delivered its much-anticipated judgment on the constitutional validity of the Greenhouse Gas Pollution Pricing Act (“GGPPA”), the statute which enacts the federal government’s carbon pricing standard. In a 6-3…
The Tax Court recently released an important decision regarding the relevance test for production of documents and information during discoveries. In Thompson Bros. (Constr.) Ltd. v. The Queen, 2021 TCC 15 (“Thompson Bros.”), the Tax Court was asked to…
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…
On April 7, 2021, the Tax Court of Canada released a further Notice to the Public and the Profession regarding its upcoming hearing schedule.
Previously, the Court had announced that a limited number of in-person hearings would proceed…
On March 3, 2021, further to statements in the Fall Economic Statement the Government of Canada confirmed its intention to further extend the Canada Emergency Wage Subsidy (CEWS) and Canada Emergency Rent Subsidy and Lockdown Support (CERS) programs through June…
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…
