In Re Pallen Trust, 2015 BCCA 222, a corporation paid a dividend to a discretionary trust on the assumption that subsection 75(2) of the Income Tax Act would attribute the income to the corporation. At the time, the general understanding…
Jennifer Flood represents clients in the most high-stakes tax disputes
Jennifer is a partner practicing in the firm’s Vancouver office. She represents companies and individuals in complex tax litigation, in both the civil and criminal contexts. She guides her clients… more »
The CRA cancelled IT-90 and released a new Income Tax Folio outlining the factors relevant to determining whether a partnership exists: “What is a partnership?” (S4-F16-C1). Comments from the public will be accepted until August 5, 2015.
Jennifer Flood represents clients in the most high-stakes tax disputes
Jennifer is a partner practicing in the firm’s Vancouver office. She represents companies and individuals in complex tax litigation, in both the civil and criminal contexts. She guides her clients… more »
In Mac’s Convenience Stores Inc. v. Canada, 2015 QCCA 837, the Quebec Court of Appeal upheld the decision of the Superior Court refusing to allow rectification of a $136 million dividend that caused adverse tax consequences the company’s tax…
Jennifer Flood represents clients in the most high-stakes tax disputes
Jennifer is a partner practicing in the firm’s Vancouver office. She represents companies and individuals in complex tax litigation, in both the civil and criminal contexts. She guides her clients… more »
Parliament has passed the government’s controversial Bill C-51, enacting the Security of Canada Information Sharing Act. A related amendment to subsections 241(9) and (10) of the Income Tax Act gives CRA officials the power to share taxpayer information with…
Jennifer Flood represents clients in the most high-stakes tax disputes
Jennifer is a partner practicing in the firm’s Vancouver office. She represents companies and individuals in complex tax litigation, in both the civil and criminal contexts. She guides her clients… more »
The CRA released a compilation of its positions on interest deductibility under paragraph 20(1)(c) and other provisions in a new Income Tax Folio, “Interest Deductibility” (S3-F6-C1), which cancels IT-533. Comments from the public will be accepted until June 6,…
Jennifer Flood represents clients in the most high-stakes tax disputes
Jennifer is a partner practicing in the firm’s Vancouver office. She represents companies and individuals in complex tax litigation, in both the civil and criminal contexts. She guides her clients… more »
