On September 14, 2015, the Department of Finance released its Annual Financial Report of the Government of Canada, in which it reported that the government posted a budgetary surplus of $1.9 billion for the fiscal year ended on March 31,…
In Virginia Hillis and Gwendolyn Louise Deegan v. the Attorney General of Canada 2015 FC 1082, the plaintiffs argued that the Canada Revenue Agency’s (the “CRA”) disclosure of information related to accounts held by U.S. citizens at Canadian banks to…
In 2014-0552711E5 “Application of paragraph 251(5)(b)” dated September 16, 2015, the CRA was asked whether a non-binding letter of intent could engage paragraph 251(5)(b) of the ITA. The CRA commented that if the letter of intent constitutes a contract…
In Remtilla v. The Queen (2015 TCC 200) V.A. Miller J determined that T1 adjustment request filed by a taxpayer’s representative constituted valid waivers of the normal reassessment period. The court found that a valid waiver must include all…
In 145257 Ontario Inc. v. The Queen, 2015 DTC 1160 (TCC), Lyons J found that a dissolved corporation incorporated under the Ontario Business Corporations Act (the “OBCA”) must be revived before it can carry on a tax appeal. Though the…