Those of us who work in Toronto and enjoy the privilege of driving to work here need no reminders about the hazards of driving anywhere these days. With the post winter construction season now in full swing here, parts of…
Two items crossed my desk at about the same time last week and I found the juxtaposition of them provocative. The first is the report of the Tax Court’s decision in Zsebok, 2012 TCC 99; the other is CRA technical…
It seemed to me today as I read another Tax Court decision on penalties that there have been a lot of them this year. A quick search of one of the case law data bases for “penalty” and “due diligence”…
A growing number of developed countries are looking for ways to beef up their anti-avoidance rules. According to a recent note in Tax Notes International (April 23, 2012), the Italian government proposes to introduce a general definition of abuse of…
A corporation that qualifies as a CCPC enjoys a number of benefits under the Act. One has to do with the right to claim refundable ITCs in respect of qualified scientific and experimental research activities. If the corporation is funded…