The Federal Court of Appeal (the “FCA”) recently released its highly anticipated decision in Canada v. Deans Knight Income Corporation, 2021 FCA 160. The case represents the FCA’s first consideration of an alleged abuse of the “control” threshold for…
In Alexander College Corp. v. Canada, 2016 FCA 269, the Federal Court of Appeal recently overturned the Tax Court of Canada on the issue of whether a private college offering an associate degree program must charge GST on its…
The Federal Court of Appeal (FCA) recently released its reasons in MNR et al v. JP Morgan Asset Management (Canada) Inc.¸ 2013 FCA 250. In lengthy reasons, the FCA takes the opportunity to express its exasperation with the many applicants…
In one of his first decisions on the bench of the Tax Court of Canada, recent appointee Justice Randall Bocock wasted no time showing his teeth: see O’Dwyer v. The Queen, 2012 TCC 261.
On a motion by the Appellant…