Tax Alert Archives April 2014

FCA Interprets Section 95(6)(b) of the Income Tax Act (Canada)

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…

Prepared by: Rebecca Potter

Rebecca Potter is a partner practicing in the firm’s Toronto office. Her practice focuses on all aspects of taxpayer representation and tax litigation and also includes tax planning for not-for-profit organizations, and charities. She has appeared before the Tax Court… more »

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TCC Dismisses Taxpayer’s Motion in McIntyre

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…

Prepared by: Rebecca Potter

Rebecca Potter is a partner practicing in the firm’s Toronto office. Her practice focuses on all aspects of taxpayer representation and tax litigation and also includes tax planning for not-for-profit organizations, and charities. She has appeared before the Tax Court… more »

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CRA Issues Technical Interpretation on Distributions by ULCs

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.

Prepared by: Rebecca Potter

Rebecca Potter is a partner practicing in the firm’s Toronto office. Her practice focuses on all aspects of taxpayer representation and tax litigation and also includes tax planning for not-for-profit organizations, and charities. She has appeared before the Tax Court… more »

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SCC Dismisses Leave Application in GF Partnership Case

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…

Prepared by: Rebecca Potter

Rebecca Potter is a partner practicing in the firm’s Toronto office. Her practice focuses on all aspects of taxpayer representation and tax litigation and also includes tax planning for not-for-profit organizations, and charities. She has appeared before the Tax Court… more »

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