The Tax Court’s decision in Landbouwbedrijf Backx B.V. v. Canada, 2021 TCC 2 is a reminder to taxpayers that just because their filing position in a tax return is accepted by the Minister of National Revenue (the “Minister”), it…
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…
The Tax Court of Canada recently released its decision in Hansen v. The Queen, 2020 TCC 102, the latest in a quickly growing body of caselaw dealing with “house flips”. The case dealt with a taxpayer, Mr. Hansen, who…
The recent decision of Bishara c. Agence du revenu du Québec[1] is a win for a taxpayer on the sale of three condominiums in quick succession. This decision is unusual because the Quebec Court of Appeal (“QCA”) reversed the decision…
At the end of March, the BC Supreme Court released its decision in Chemainus Gardens RV Resort Ltd. v The Queen, 2020 BCSC 478. The decision is potentially of great assistance to contractors in BC who install goods that become…
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On July 27, 2020, Parliament enacted Bill C-20 which made sweeping amendments to the Canada Emergency Wage Subsidy (the “CEWS”). The…
Chief Justice Rossiter of the Tax Court of Canada has now outlined multiple aspects of the Court’s process for reopening, following its lengthy closure due to COVID-19, by issuing a Practice Direction and Order and Notice to the…
Below is a summary of the implications of the COVID-19 pandemic on tax audits and disputes as of June 15, 2020. A link to the CRA’s most up-to-date administrative policies regarding COVID-19 can be found here.
CRA audit activity…
The decision in Grewal v Canada (National Revenue) involved a taxpayer being penalized in respect of amounts disclosed in a voluntary disclosure, despite the fact that the disclosure was accepted by the Canada Revenue Agency (“CRA”).
This case addressed…
Below is a summary of the implications of the COVID-19 pandemic on tax audits and disputes as of May 1, 2020. A link to the CRA’s most up-to-date administrative policies regarding COVID-19 can be found here.
Taxpayers under audit…