Moore v. Getahun: Expert Witnesses
On January 29, 2015, the Ontario Court of Appeal released its widely-anticipated reasons in Moore v. Getahun (2015 ONCA 55). […]
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ConocoPhillips: FCA Confirms Tax Court’s Jurisdiction to Determine Questions of Timing and the Validity of a Notice of Objection
In ConocoPhillips Canada Resources Corp. v. The Queen (2014 FCA 297), the Federal Court of Appeal overturned a Federal Court decision (2013 […]
Brent Kern Family Trust: FCA Dismisses Appeal
In Brent Kern Family Trust v. The Queen (2014 FCA 230), the Federal Court of Appeal dismissed the taxpayer’s appeal […]
Foreign Charities and the Changing Landscape of CRA Charity Audits
There has been a flurry of recent scrutiny and activity in the areas of foreign and domestic charities – few […]
B.C. Supreme Court Rescinds Land Transfers
In Re 0741508 BC Ltd and 0768723 BC Ltd (2014 BCSC 1791), the British Columbia Supreme Court (“BCSC”) considered whether rescission should […]
Bolton Steel Tube: TCC Orders Crown to Reassessment in Accordance with Settlement
In Bolton Steel Tube Co. Ltd. v. The Queen (2014 TCC 94), the Tax Court of Canada allowed the taxpayer’s […]
Roitelman: Fraud and the Due Diligence Defence
In Roitelman v. The Queen (2014 TCC 139), the Tax Court considered whether a director could establish that he had […]
Regulation of Bitcoin Around the World
Governments and tax authorities continue to develop their fiscal and tax positions relating Bitcoins. Many countries are releasing warnings about […]
Emerging Markets: Non-EU Investment Funds Eligible for Withholding Tax Refund
In Emerging Markets Series of DFA Investment Trust Company (C -190/12), the European Court of Justice (ECJ) confirmed that investment funds […]
McIntyre: Not What You Bargained For?
When are the parties to a civil tax dispute bound by agreed facts from a criminal proceeding? This was the […]
IRS: Bitcoin Not a Currency for Tax Purposes
As expected, the U.S. Internal Revenue Service has provided some guidance on the U.S. tax treatment of Bitcoin. In Notice […]
SCC Grants Leave to Appeal in Guindon v. The Queen
The Supreme Court of Canada has granted leave to appeal in Guindon v. The Queen (Docket # 35519). In this […]
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