In the recent Tax Court case of Trudy Tallon v. the Queen, Woods, J. was asked to rule on travel and transportation medical expenses tax credits claimed under paragraphs 118.2(2)(g) and (h) by the taxpayer in her 2009 taxation year. …
On October 23, 2013, Prime Minister Stephen Harper and European Commission President José Manual Barroso signed an agreement-in-principle relating to the Comprehensive Economic and Trade Agreement (“CETA”). This agreement provides for the removal of nearly all customs duties and tariffs…
Is aggressive tax avoidance immoral? Some people think so, but I don’t. (I’ve been on this topic before – see my blog post, June 5, 2013, “Tax Planning, Morality and Cowboys”). The bottom line for me is this: if…
I’ve been asking myself this question a lot this year. Partly it’s due to the discussion now going on in tax circles about the possibility of broad based international tax reform. In part, too, it’s prompted by my growing fatigue…
Forgive me for saying this about a government publication, but Canada’s Taxpayer Bill of Rights (TBR) really is a misleading document. It styles itself as a “Bill of Rights,” but it can’t be enforced in any legal way. The recent…
“In quantifying a taxpayer’s tax liability under the Income Tax Act… is it ever necessary to evaluate the morality of a taxpayer’s conduct? As a matter of general principle, the answer should be no…. nothing in the Income Tax Act…
“The Government will monitor developments in this area and, if structures or transactions emerge that undermine the effectiveness of the measure, evaluate whether further action is warranted, with possible retrospective application.” (My emphasis.)
“The Government will…
The federal budget last week (March 21) provoked the usual range of comment and criticism from the media, members of the opposition parties, and the blogosphere. I read very little discussion of the traditional idea that budgetary proposals are to…
A recent decision of the Tax Court is at times interesting, surprising and disturbing. The case – Swirsky v R, 2013 TCC 73 – raises an important question about the scope of paragraph 20(1)(c) of the Income Tax Act. That…
There’s been a lot in the news recently about appropriate responses to tax avoidance schemes. The OECD has just released a report on tax base erosion and profit shifting (February, 2013) which was endorsed by the G-20 Finance Ministers in…