Publications

The Source Doctrine is the Sauce for Confusion in Tax Law

  The Source Doctrine is the Sauce for Confusion in Tax Law By Vern Krishna, CM, QC   When it comes to taxation, Canadians investors…

Revisiting Intent in Employee/Independent Contractor Determination

Revisiting Intent in Employee/Independent Contractor Determination By: Michael Thomson and David Piccolo   On January 14, 2014, the Tax Court of Canada released their decision…

Supreme Court Releases Decision in Craig

Supreme Court Releases Decision in Craig On August 1, 2012, the Supreme Court released a unanimous decision written by Justice Rothstein in Canada v. Craig, 2012 SCC 43. …

Canadian GAAR Update

On December 16, 2011, the Supreme Court of Canada released the long-awaited decision in the Copthorne Holdings Ltd case.  For the benefit of our colleagues,…

When preparatory activities become business?

In Walsh, 2011 TCC 341 the Tax Court deal with a fundamental issue: when preparatory activities undertaken by a taxpayer towards establishing a business become…

Tax Disputes

Tax Disputes On April 7, 2011, the Globe & Mail posted a blog entry in the “Home Cents” Blog on the right way to deal with tax…

Daimler and Transfer Pricing

Daimler and Transfer Pricing According to a report in the February 28, 2011 edition of the Globe and Mail, Daimler AG will pay approximately US$1.5 billion…

Ebay Businessperson Convicted

On August 27, 2010, CRA announced that they had convicted an individual for failing to report business income from their business selling fur coats on eBay….

Ottawa to Combat Losses on Income Trusts

According to a report in the January 27, 2010 National Post, income trusts have been merging with corporations that have tax losses as a means of…

Employee v Independent Contractor

One common issue facing businesses of all sizes is how they should organize their human resources – should they be employees or independent contractors. From…

Canadian Brokerage Firm Linked to Offshore Accounts

According to a report in the December 14, 2009 The Globe and Mail, the Canada Revenue Agency (CRA) is investigating the involvement of staff from RBC…

HST Transitional Rules

On December 9, 2009, the Ontario Legislature passed its controversial bill implementing the HST in Ontario. Starting July 1, 2010, a 13% HST will be applied…