The Supreme Court of Canada dismissed the appeal of the taxpayer in Guindon v The Queen, 2015 SCC 41. The majority of the Court exercised its discretion to address the merits of the taxpayer’s constitutional arguments despite the taxpayer’s…
Florence Sauve is a partner in the Toronto office of Thorsteinssons LLP.
Florence’s practice focuses on all aspects of taxpayer representation. She assists her clients in managing and resolving tax audit and appeal disputes and represents her clients before the… more »
In Zhang v Canada (Attorney General), 2015 BCSC 1256, the Supreme Court of British Columbia dismissed an application for rectification on the basis that the petitioners failed to establish that they had a specific continuing intention to avoid the…
Florence Sauve is a partner in the Toronto office of Thorsteinssons LLP.
Florence’s practice focuses on all aspects of taxpayer representation. She assists her clients in managing and resolving tax audit and appeal disputes and represents her clients before the… more »
In 2014-0563081R3 and 2014-0526431R3 (in French), the Canada Revenue Agency issued advance income tax rulings confirming that subsections 84(2) and 245(2) of the Income Tax Act (Canada) would not apply as a result of proposed transactions implementing post-mortem…
Florence Sauve is a partner in the Toronto office of Thorsteinssons LLP.
Florence’s practice focuses on all aspects of taxpayer representation. She assists her clients in managing and resolving tax audit and appeal disputes and represents her clients before the… more »
On July 9, 2015, the Supreme Court of Canada dismissed the application for leave to appeal from the decision in Lyrtech RD Inc. v The Queen, 2014 FCA 267 in which the Federal Court of Appeal upheld the…
Florence Sauve is a partner in the Toronto office of Thorsteinssons LLP.
Florence’s practice focuses on all aspects of taxpayer representation. She assists her clients in managing and resolving tax audit and appeal disputes and represents her clients before the… more »
On July 10, 2015, the CRA released Income Tax Folio S4-F2-C1, “Deductibility of Fines and Penalties”, which replaces and cancels former Interpretation Bulletin IT-104R3. In addition to consolidating the content of the former Interpretation Bulletin, the Chapter Folio discusses…
Florence Sauve is a partner in the Toronto office of Thorsteinssons LLP.
Florence’s practice focuses on all aspects of taxpayer representation. She assists her clients in managing and resolving tax audit and appeal disputes and represents her clients before the… more »
This is a reminder that the phasing out of the requirement for certain large businesses to recapture the provincial portion of Ontario HST claimed as input tax credits in respect of specified property and services has started on July 1,…
Florence Sauve is a partner in the Toronto office of Thorsteinssons LLP.
Florence’s practice focuses on all aspects of taxpayer representation. She assists her clients in managing and resolving tax audit and appeal disputes and represents her clients before the… more »
In Paul L. Schnier v. Her Majesty the Queen, the Tax Court of Canada dismissed the motion brought by the Respondent under Rule 53(3)(c) of the Tax Court of Canada Rules (General Procedure) to quash the appeal on the basis…
Florence Sauve is a partner in the Toronto office of Thorsteinssons LLP.
Florence’s practice focuses on all aspects of taxpayer representation. She assists her clients in managing and resolving tax audit and appeal disputes and represents her clients before the… more »
