Author: Sarah Faber

Marine Atlantic v The King – What is a “fair and reasonable” allocation in a business when everything depends on everything?

Published by Sarah Faber

When is an allocation of costs amongst supplies “fair and reasonable” for calculating input tax credits (“ITCs”)? In Marine Atlantic Inc. v The King (2023 TCC 95), the Tax Court confirmed that a “fair and reasonable” allocation:

  1. is based

Loblaw Financial: SCC dismisses Crown appeal and affirms importance of text and context in interpreting tax provisions

Published by Sarah Faber

On December 3, 2021, a unanimous Supreme Court of Canada (“SCC”) dismissed the Crown’s appeal in Canada v. Loblaw Financial Holdings Inc. (2021 SCC 51). In doing so, the Court held that capital contributions and corporate oversight are not relevant…