Westerhoff and McCallum: More from the OCA on Expert Evidence
The Ontario Court of Appeal released its decision last week in Westerhof v. Gee Estate and McCallum v. Baker (2015 […]
Tax Court of Canada
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 […]
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 […]
Out with the Old, In with the New: Clearwater Seafoods Holdings Trust v. The Queen
In the recent decision in Clearwater Seafoods Holdings Trust (2013 FCA 180), the Federal Court of Appeal considered the scope and […]
The importance of a notice of objection: Salisbury v. The Queen
In Salisbury House of Canada Ltd. et al. v. The Queen (2013 TCC 236), the Tax Court of Canada reiterated the […]
Taxpayer entitled to disclosure of the “policy” underlying statutory provisions allegedly abused in GAAR cases
On December 20, 2012, the Tax Court ruled on a motion under Rule 52 of the Tax Court of Canada Rules […]
Taxpayer wins an important and complex case – Tax Court orders CRA to pay 60% of his out-of-pocket costs
Traditionally in a Tax Court appeal the costs awarded to a successful taxpayer have been no more than a small […]
No Medal for CRA’s Questionable Treatment of Canadian Olympic Medalists
On August 13 I came across this article in the Globe and Mail outlining how CRA treated prizes received by […]
Federal Court of Appeal Reserves Judgment in Transalta Corporation v. The Queen (Allocation of Goodwill in Arm’s-Length Transaction)
The Federal Court of Appeal heard the appeal in Transalta Corporation v. The Queen (Court File No. A-350-10) on December 13, […]
Tax Court of Canada: The GAAR Does Not Apply to Disallow Deduction of a $5.6 Million Business Loss
On October 28, 2011 the Tax Court of Canada released Judgment and Reasons for Judgment of the Honourable Justice Judith Woods in […]
Tax Court of Canada Authorizes Commission Evidence to be Taken in the U.S. on an Art Valuation Case: Sackman v. The Queen
On October 21, 2011, the Tax Court of Canada (Justice Valerie Miller) released her decision on a motion brought by […]