Tax Alert Archives July 2012

Federal Court of Appeal Releases its Decision in Important Attribution Case

On July 13th, 2012, the Federal Court of Appeal dismissed the Crown’s appeal in The Queen v Peter Sommerer (2012 FCA 207).

The facts are not complex. In 1996, Peter Sommerer’s father, Herbert Sommerer, created an Austrian private foundation of…

Prepared by: E. Rebecca Potter

Becky Potter is a partner practicing in the firm’s Toronto office. Known for her strategic approach, honed advocacy skills, and breadth of tax knowledge, Becky Potter is a highly sought-after tax litigator. She has successfully represented her clients at every… more »


NPO “Education” Letters

The Canada Revenue Agency (the “CRA”) has confirmed that a large scale information gathering project is underway in respect of not-for-profits (NPOs) and their income-generating activities. Between 2010 and 2013, Specialty Audit is coordinating the audit of 1440 randomly selected…


CRA Challenging Individual Pension Plans (IPPs)

The Canada Revenue Agency (“CRA”) has recently mailed detailed audit request letters to members of certain individual pension plans (“IPPs”). The letters appear to be connected to an ongoing audit program targeting IPPs.

As background, an IPP is a defined…

Prepared by: Brent Pidborochynski

Brent Pidborochynski is a partner at Thorsteinssons LLP. His practice includes both domestic and international tax planning, corporate reorganizations, private equity transactions, trusts and estate planning for high net worth individuals. Brent also advises clients on tax disputes with the… more »