Bousfield v. The King, 2022 TCC 169, is a recent decision of the Tax Court of Canada that addresses “alternative assessment techniques”. The decision serves as a helpful guide to both the legal bases for such techniques and the…
Khanna v. The Queen, 2022 FCA 84 is an important decision of the Federal Court of Appeal (the “FCA”) on the topic of gross-negligence penalties imposed under subsection 163(2) of the Income Tax Act (Canada) (the “Act”). The decision…
The Tax Court’s decision in Leonard v. The Queen, 2021 TCC 33, analyzed the oft-discussed legal concept of “an adventure or concern in the nature of trade”, which the courts use to distinguish between transactions of a business nature…
The Tax Court of Canada recently released its decision in Hansen v. The Queen, 2020 TCC 102, the latest in a quickly growing body of caselaw dealing with “house flips”. The case dealt with a taxpayer, Mr. Hansen, who…
On June 23, 2020, the CRA released its National Business Resumption Plan (the “NBRP”) for CRA employees. This follows the CRA’s previous announcement that it would be transitioning from a critical services mode to a business resumption mode on June…
The latest chapter in the story of the “half-loaf plan” has been penned by the Federal Court of Appeal in Gervais v. the Queen, 2018 FCA 3. The case dealt with a plan by which the taxpayer, Mr. Gervais,…
The Federal Court of Appeal recently released its decision in Canada (National Revenue) v. ConocoPhillips Canada Resources Corp., 2017 FCA 243. The background for the case is as follows: ConocoPhillips had been issued a reassessment of its 2000 taxation…