Tax Alert Archives February 2012

FCA Clarifies Purchase Price Allocation Principles

Section 68 of the Income Tax Act (Canada) (the “ITA”) allows the Canada Revenue Agency (the “CRA”) to determine the reasonable consideration for the disposition of a particular property. In TransAlta Corporation v. The Queen (2012 FCA 20), the Federal…

Prepared by: Shane Brown

Shane Brown is a partner practising out of the Vancouver office of Thorsteinssons LLP. Shane’s practice focuses on domestic and international tax planning for individuals, trusts, corporations and charities, including: estate planning, corporate reorganizations, divisive reorganizations, business structuring, property acquisitions… more »


Punitive TFSA Audits

The Canada Revenue Agency (“CRA”) has recently begun mailing out questionnaires to individuals holding significant amounts in their Tax-Free Savings Accounts (“TFSAs”). This appears to be part of a project audit of TFSAs across the country. A copy of one…

Prepared by: David Davies , Alexander Demner, TEP

David is a tax litigator who specializes in challenging adverse tax reassessments issued by the Canada Revenue Agency. His Philosophy An English judge once wrote that “every person is entitled to order his (or her) affairs so that the tax… more »

Alexander is a partner practicing in the firm’s Vancouver office. Alexander’s practice covers several areas of taxation, including estate planning, pre-sale and divestiture structuring, owner-manager remuneration, taxpayer representation, and tax litigation. Alexander routinely advises on and implements reorganizations for individuals,… more »