Tags » Income Tax Act

Standard Life v. R. - TCC: $1.2 billion asset bump “mere window dressing designed to mislead the Minister”.


Standard Life Assurance Company of Canada v. The Queen (April 20, 2015 – 2015 TCC 97, Pizzitelli J.).

Précis: Prior to 2006 Standard Life Assurance Company of Canada (“Standard”) only carried on a life insurance business in Canada. 2,433 more words

Tax Litigation

Sowa v. R. – FCA: Appeal of inadequate/bogus tax receipt dismissed from the bench.


Sowa v. Canada (April 21, 2015 – 2015 FCA 103, Nadon, Dawson (author), Boivin JJA).

Précis: This is a decision on an appeal from a Tax Court decision reported as… 206 more words

Income Tax Act

Kruger Wayagamack Inc. v. R. – TCC: Taxpayer controlled by Kruger Inc. with 51% shareholdings.


Kruger Wayagamack Inc. v. The Queen (April 14, 2015 – 2015 TCC 90, Jorré J.).

Précis: This is somewhat of an oddball case involving entitlement to refundable SRED credits. 427 more words

Tax Litigation

R. v. Martin – FCA: Tax Court cannot award costs for “inconsistent and irrational” conduct by CRA.


Canada v. Martin (April 15, 2015 – 2015 FCA 95, Dawson (author), Webb, Near JJA).

Précis: This is a decision on an appeal by the Crown from a costs award made by Justice Boyle in the Tax Court. 1,488 more words

Tax Litigation

Nanica Holdings Limited v. R. – TCC: Dividend refunds need to be paid in order to erode a corporation’s RDTOH balance.


Nanica Holdings Limited v. The Queen (April 10, 2015 – 2015 TCC 85, V. Miller J.).

Précis: The taxpayer claimed dividend refunds in 2011 and 2012 which were partially denied by CRA. 813 more words

Tax Litigation

Finanders v. R. – FC: CRA decision to deny relief of penalties on long term disability income unreasonable.


Finanders v. Canada (Attorney General) (April 13, 2015 – 2015 FC 448, O’Keefe J.).

Précis: Ms. Finanders received and reported short term disability income she received in 2008. 809 more words

Income Tax Act