Tax Alert Archives February 2021

Ontario Court of Appeal unpersuaded by principle that governments have the right to legislate “illogically”

In Stonehouse Group Inc. v. Ontario (Minister of Finance), 2021 ONCA 10, a taxpayer was successful in its dispute with the Ministry of Finance. As a result, a refund of the reassessed taxes was paid. The Minister of Finance…

Prepared by: Leonard Gilbert , Morgan Watchorn

Leonard graduated from the University of Toronto, Faculty of Law (J.D. 2015) and is currently a partner practicing in the firm’s Toronto office. He previously performed extensively as a concert pianist and attended the Jacobs School of Music at Indiana… more »

Morgan Watchorn is an associate working out of the Vancouver office of Thorsteinssons LLP. Morgan earned her Juris Doctor from Thompson Rivers University. While in law school, she competed in the Bowman National Tax Moot and worked as a teaching… more »

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CRA not providing relief where COVID-related delays create difficulties in meeting deadline for s. 164(6) loss carrybacks within estate’s first taxation year

In CRA Technical Interpretation 2020-0865071E5, the CRA was asked whether it would allow more time for the application of s. 164(6) of the Income Tax Act (Canada) where COVID has resulted in delays regarding the administration of an estate.  The…

Prepared by: Leonard Gilbert , Morgan Watchorn

Leonard graduated from the University of Toronto, Faculty of Law (J.D. 2015) and is currently a partner practicing in the firm’s Toronto office. He previously performed extensively as a concert pianist and attended the Jacobs School of Music at Indiana… more »

Morgan Watchorn is an associate working out of the Vancouver office of Thorsteinssons LLP. Morgan earned her Juris Doctor from Thompson Rivers University. While in law school, she competed in the Bowman National Tax Moot and worked as a teaching… more »

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Tax Court of Canada provides clarity on timing of allocating costs between different taxation years

In Yorkwest Plumbing Supply Inc. v. The Queen, 2020 TCC 122, due to a switch in the appellant’s accounting system the cost of inventory was not properly allocated against the cost of sales. The appellant attempted to overstate its…

Prepared by: Leonard Gilbert , Morgan Watchorn

Leonard graduated from the University of Toronto, Faculty of Law (J.D. 2015) and is currently a partner practicing in the firm’s Toronto office. He previously performed extensively as a concert pianist and attended the Jacobs School of Music at Indiana… more »

Morgan Watchorn is an associate working out of the Vancouver office of Thorsteinssons LLP. Morgan earned her Juris Doctor from Thompson Rivers University. While in law school, she competed in the Bowman National Tax Moot and worked as a teaching… more »

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Federal Court of Appeal finds that a corporation must be represented by counsel in tax appeals

In Canada v. BCS Group Business Services Inc., 2020 FCA 205, the Federal Court of Appeal held that a corporation cannot not appear “in person” and must be represented by counsel in appeals under the Tax Court’s General Procedure.…

Prepared by: Leonard Gilbert , Morgan Watchorn

Leonard graduated from the University of Toronto, Faculty of Law (J.D. 2015) and is currently a partner practicing in the firm’s Toronto office. He previously performed extensively as a concert pianist and attended the Jacobs School of Music at Indiana… more »

Morgan Watchorn is an associate working out of the Vancouver office of Thorsteinssons LLP. Morgan earned her Juris Doctor from Thompson Rivers University. While in law school, she competed in the Bowman National Tax Moot and worked as a teaching… more »

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COVID-19 Tax Update: Updates from the Tax Court

On February 9, 2021, Chief Justice Eugene Rossiter of the Tax Court of Canada held a webinar to update the public on the Court’s current status and outlook as a consequence of the COVID-19 pandemic.

The Tax Court previously announced…

Prepared by: Tyler Berg

Tyler is an Associate working in the Vancouver office. Tyler attended the Peter A. Allard School of Law at the University of British Columbia, where he completed the Juris Doctor program and the Business Law Concentration.  He competed in the… more »

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