Greg DelBigio, Q.C. has advised and acted on behalf of individual taxpayers, corporations and tax advisors during audits, criminal investigations and after criminal charges have been approved. Read complete profile »
Under the provisions of the Income Tax Act (the “ITA”), the CRA is authorized to inspect a taxpayer’s books and records and to require taxpayers to provide information and documents in the course of an income tax audit. However, the…
I last wrote about the decision in BP Canada Energy Company v. Canada (National Revenue), 2017 FCA 61 on April 10, 2017. In that decision the Court imposed important restrictions upon the use of the s.231.1(1) audit powers by…
The Income Tax Act provides CRA with broad powers of administration and enforcement. In BP Energy Company v. Minister of National Revenue, 2017 FCA 61, the appeal court considered the authority to conduct the inspection of books and records given…
If a year is to end with something that causes a bang, then the decision in Minister of National Revenue v. Iggillis Holdings Inc. and Ian Gillis Et Al., 2016 FC 1352 did just that. In reasons that are ambitious,…
It used to be that the favorite topic of conversation in Vancouver, and then more recently in Toronto was the cost of real estate. There was unending speculation on how high the prices might go and whether the party would…
I have had many hours of spirited conversation with my friend and colleague, Craig Sturrock Q.C., over the extent to which, or the way in which the Charter of Rights applies in tax law. In broad strokes, his position has…
As part of Budget 2016 the government announced that it is “committed to preventing underground economic activity, tax evasion and aggressive tax planning.” To achieve this, the budget proposes to allocate $444.4 million over five years to enable CRA to…
A spring break holiday provides one with a good opportunity to catch up on reading and to reflect upon basics. In this instance, the reading was the tax fraud prosecution of R. v. Khan and Muellenbach (2015 ONSC 7283) and…
The recent case of Boroumand v. The Queen 2015 TCC 239 neatly illustrates just how challenging a forum the Tax Court can be for certain appellants. The facts of the case are unremarkable and common enough: the appellant was brought…
It is not often that tax cases wind their way to the Supreme Court of Canada so both that Court’s judgments on specific points of tax law, as well as it’s more general observations about tax law are of interest.…