In Canada v Paletta Estate (“Paletta FCA”), a unanimous panel of the Federal Court of Appeal (the “FCA”) overturned the decision of the Tax Court of Canada (“Paletta TCC”). Our blog post analyzing Paletta TCC is found
In Canada v Dow Chemical Canada ULC, the Federal Court of Appeal (the “FCA”) confirmed that the jurisdiction of the Tax Court of Canada does not extend to varying or quashing an “opinion”. Rather, the FCA held that the…
Authors: Gloria Wang, Sarah Faber, and Alexander Demner
Budget 2022: A Plan to Grow Our Economy and Make Life More Affordable (“Budget 2022”) was tabled by the Federal Government on April 7, 2022 (“Budget Day”). The government…
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…
Last week, the Supreme Court of Canada (“SCC”) dismissed the Crown’s appeal in Canada v. Alta Energy Luxembourg S.A.R.L. (2021 SCC 49). In doing so, the SCC wrestled with important, timely, and politically contentious questions of domestic and international…
In Canada (National Revenue) v. Boguski, 2021 FCA 118 affirming 2018 TCC 236, the Federal Court of Appeal (the “FCA”) affirmed the decision of the Tax Court of Canada (the “Tax Court”) to dismiss the Minister’s application for an…
In Zeifmans LLP v. MNR, 2021 FC 363, the Federal Court considered whether a requirement for information regarding unnamed persons issued to an accounting firm was properly made under section 231.2 of the Income Tax Act (Canada) (the “ITA”).…
The Tax Court’s decision in Leonard v. The Queen, 2021 TCC 33, analyzed the oft-discussed legal concept of “an adventure or concern in the nature of trade”, which the courts use to distinguish between transactions of a business nature…
Authors: Alexander Demner, Tyler Berg, and Gloria Wang
The federal government released its 2021 budget on April 19, 2021. Coming in as the longest budget in Canadian history, Budget 2021 proposes a myriad of income tax…
In Paletta Estate v The Queen, 2021 TCC 11, the Tax Court of Canada allowed the taxpayer’s appeal in respect of “straddle” transactions undertaken in the early-2000s. In doing so, the Court expressly held that commercial activities undertaken solely…