Tags » Income Tax Act

Nguyen v. R. – TCC: Taxpayer loses appeal with respect to unreported income from a restaurant – gross penalties imposed.


Nguyen v. The Queen (Reasons delivered orally from the bench by conference call on November 11, 2014, signed January 13, 2015 – 2015 TCC 7) is a decision falling into the familiar pattern of unreported sales of a restaurant. 677 more words

Tax Litigation

568864 B.C. Ltd. v. R. – TCC: Taxpayer entitled to terminal loss on patents; Crown could not introduce documents not listed in discovery.


568864 B.C. Ltd. v. The Queen (December 29, 2014 – 2014 TCC 373) is a decision involving the taxpayer’s claim to a terminal loss of $3,871,057 on the disposition of patents in 2007 for $1.00. 2,402 more words

Tax Litigation

9016-9202 Québec Inc. v. R. – TCC: 36 incorporated garbage collectors working for former employer not entitled to small business deduction.


9016-9202 Québec Inc. v. The Queen (September 25, 2014 – 2015 TCC 281) is an example of what appears to be a fairly aggressive bit of tax planning that sought to treat all of the garbage collectors that were formerly employers of EBI Environnement inc. 1,312 more words

Tax Litigation

Andrew v. R. – TCC: Tax court rejects director’s due diligence defence in GST and income tax appeals.


Andrew v. The Queen (January 2, 2015 – 2015 TCC 1) is a case involving three director’s liability assessments against Mr. Andrew:

[1] These are appeals from three assessments made against Donald Andrew as director of Andrew Paving and Engineering Ltd. 990 more words

Tax Litigation