The Federal Court of Appeal has handed down its decision in the Lehigh Cement case on the scope of the antiavoidance rule in section 95(6)(b) of the Income Tax Act (Canada). The court concluded that “s.95(6)(b) is targeted at those…
Becky Potter is a partner practicing in the firm’s Toronto office.
Becky focuses her practice on all aspects of taxpayer representation and tax litigation. She has successfully represented clients at every level of court both provincially (in Ontario) and federally,… more »
The Tax Court of Canada recently released its decision in the McIntyre case. The court dismissed the taxpayer’s motion, holding that the Minister is not bound by agreed facts from a prior criminal proceeding involving the same taxpayer. A copy…
Becky Potter is a partner practicing in the firm’s Toronto office.
Becky focuses her practice on all aspects of taxpayer representation and tax litigation. She has successfully represented clients at every level of court both provincially (in Ontario) and federally,… more »
In technical interpretation 2013-0486931E5, the CRA recently addressed the treatment of a distribution of dividend income received from a ULC, and made by a Canadian trust to a non-resident beneficiary of that trust.
Becky Potter is a partner practicing in the firm’s Toronto office.
Becky focuses her practice on all aspects of taxpayer representation and tax litigation. She has successfully represented clients at every level of court both provincially (in Ontario) and federally,… more »
The application for leave to appeal from the Federal Court of Appeal’s decision in GF Partnership v. The Queen has been dismissed with costs by the Supreme Court of Canada. The decision related to GST and the construction of certain…
Becky Potter is a partner practicing in the firm’s Toronto office.
Becky focuses her practice on all aspects of taxpayer representation and tax litigation. She has successfully represented clients at every level of court both provincially (in Ontario) and federally,… more »