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…
On February 24, 2020, the Alberta Court of Appeal became the third court in Canada to rule on the federal government’s carbon pricing regime. Unlike previous cases in Saskatchewan and Ontario, the Alberta Court held that the…
In White v The Queen[1], the Tax Court allowed Mrs. White’s appeal, holding that the deposits of funds by Mr. White, a “tax debtor”, into a joint bank account held by him and Mrs. White (the “Joint Bank Account”) did…
In Canada v Rio Tinto Alcan[1], the Federal Court of Appeal (“FCA”) upheld the Tax Court of Canada (“TCC”) decision[2] confirming, inter alia, the deductibility of certain takeover expenses incurred by Rio Tinto Alcan Inc. (“Alcan”) in its takeover of…
On September 20, 2019, the Federal Court of Appeal (“FCA”) released its decision in Tedesco v. Canada (2019 FCA 325) (“Tedesco”), overturning the decision at the TCC of Canada (“TCC”) (heard as Stewart v. The Queen, 2018 TCC 75). The…
On June 28, 2019, the Ontario Court of Appeal released its decision on the Ontario government’s reference regarding the constitutionality of the federal carbon pricing regime. Like the Saskatchewan Court of Appeal ruled in May, the majority of the…
On May 3, 2019, the Saskatchewan Court of Appeal released its decision in the Saskatchewan government’s reference asking it if the federal “carbon tax” is unconstitutional. The Court held that the federal legislation was validly enacted under the
The BC government’s recent focus on tax evasion and money laundering in the real estate market has led to proposed legislation, the Land Owner Transparency Act (Bill 23 – 2019), which will impose potentially onerous disclosure requirements on those who…
The Australian Taxation Office (ATO) recently announced that, through a consultation process, it is examining the use and, more particularly, what it says are occasions of misuse of claims of solicitor-client privilege. The Consultation is interesting but, it also provides…