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…
In the 2018 Federal Budget, the Department of Finance released another chapter in its saga to overhaul how private corporations and their shareholders are taxed. Finance’s initial consultation paper of July 18, 2017 (see our summary here) was met…
On October 13, 2017, the Federal Court of Appeal released its decision in Univar Holdco Canada ULC. v. H.M.Q. 2017 FCA 207 (“Univar”), overturning the trial decision at the Tax Court of Canada (2016 TCC 159). The judgment contained several…
“Rectification”, a means to “fix” a mistake made in the implementation of an agreement, has been a popular topic in tax law since the Supreme Court of Canada’s decisions limiting the availability of rectification for tax planning errors in AG…
In a rather bold move, the taxpayer in Coast Capital Savings Credit Union v. Canada (2015 TCC 195) claimed that it was the victim of a “sham” and sought to amend its notice of appeal on a motion before the…