Tags » Income Tax Act

SCC grants CRA leave to appeal QCA decision voiding requirements served on advocates and notaries of Quebec.

The Supreme Court of Canada granted leave today, December 18, 2014, to CRA to appeal the decision of the Quebec Court of Appeal limiting sections 232.2(1), 231.7 and the exception set out the definition of solicitor-client privilege” in subsection 232(1) of the… 347 more words

Tax Litigation

International Tax Review Names Justice Patrick Boyle (Silver) and McKesson Canada (Bronze) to Global Tax 50 for 2014.

In a perhaps somewhat ironic twist International Tax Review has named both the Hon. Mr. Justice Patrick Boyle (Silver Tier) and McKesson Canada (Bronze Tier) to its 2014 annual list of the most influential members of the international tax community.  61 more words

Tax Litigation

Elbadawi v. R. – TCC: Crown awarded costs and disbursements of $86,240.14 to sanction conduct of taxpayer.


Elbadawi v. The Queen (August 27, 2014 – 2014 TCC 363) was an extremely rare example of the Crown being awarded virtually all of its costs on a solicitor-client basis (it had sought a lump sum award of $88,000). 649 more words

Tax Litigation

Bérubé v. R. – Taxpayer could not appeal a nil assessment.


Bérubé v. The Queen (October 24, 2014 – 2014 TCC 304) is a somewhat lengthy (81 paragraphs) decision which concludes by applying the well known rule that a taxpayer cannot appeal a nil assessment. 8 more words

Tax Litigation

Thompson v. Canada SCC: Solicitor-Client Privilege in Tax Enforcement Proceedings

By Jonathan Di Feo

Thompson v. Canada (The Minister of Revenue) was heard before the Supreme Court of Canada on December 4, 2014. This case can have several repercussions regarding the enforcement of the Income Tax Act (ITA). 1,230 more words

Accounts Receivable

Barrasso v. R. – TCC: Another value shifting structure fails to survive GAAR attack.


Barrasso v. The Queen (May 5, 2014, 2014 – 2014 TCC 156) was another value shifting tax structure case similar to two that the Federal Court of Appeal decided against taxpayers in 2012, … 964 more words

Tax Litigation