On November 10, 2011 the Federal Court of Appeal (FCA) released its decision in Imperial Tobacco Canada Limited v. The Queen, 2011 FCA 308. The issue for the Court to determine was whether $118 million paid by the taxpayer to…
On October 13, 2011, the Supreme Court of Canada (SCC) granted leave to appeal in Agence du Revenu du Québec (formerly the Deputy Minister of Revenue of Quebec) v. Services Environnementaux AES Inc., Centre Technologique AES Inc. The central issue in this…
On July 12, 2011, the Tax Court of Canada (TCC) released the long-awaited decision in Triad Gestco Ltd. v. The Queen, 2011 TCC 259. This is the TCC’s most recent decision concerning the application of the general anti-avoidance rule (GAAR).…
The Federal Court of Appeal recently released its much-anticipated decision in Bozzer v. The Queen, 2011 FCA 186. Since the introduction in 2004 of a 10-year limitation period for interest and penalty relief under subsection 220(3.1) of the Income…