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…
The Supreme Court of Canada has been unequivocal in its affirmation of the importance of the protection of solicitor-client privilege. For example, in R. v. McClure, 2001 SCC 14 the Court held (at para.35) that the privilege “must be as…
There can be no doubt that the intentional suppression of sales data, whether through use of an electronic device (often referred to as a “zapper”) or through use of an eraser on the end of a pencil might constitute criminal…
In his Blog posting “Finance Releases Proposed Amendments” (15 July 2013), my colleague Ian Gamble discussed several of the legislative proposals recently made by the Minister of Finance.
The proposals also include suggested amendments to s.241 of the Income Tax Act…
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…
The Federal Court of Appeal’s recent decision in The Queen v. Guindon attempts to answer the question: when is an intentional action criminal in nature? In Guindon, the taxpayer signed 153 charitable donation receipts in what was characterized by the…
“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 Province of Québec has announced the details of a new mining tax regime. The new regime will be implemented in 2014, and follows on the heels of other changes that the Province of Québec has made to its mining…
The following blog was co-written by Greg DelBigio and Leah Plumridge:
The Canada Revenue Agency (“CRA”) now has easier access to confidential taxpayer records as a result of a recent British Columbia Supreme Court decision, Canada Revenue Agency v.…
The following blog was joint collaboration by Greg DelBigio, David Thompson, James Murdoch, and Steve Cook:
Last week saw tax law become the subject of international headlines. Media outlets excitedly announced that as a result of a “leak” of documents the…