Recently, the Alberta Court of Appeal released their decisions in Husky Energy Inc. v Alberta and Canada Safeway Limited v Alberta. The appeals addressed the…
In Hine v The Queen (2012 TCC 295), the application of the gross negligence penalty for the 2006 taxation year was the sole tax issue…
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. …
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,…
2011 OFFSHORE VOLUNTARY DISCLOSURE INITIATIVE MAY HELP U.S. CITIZENS RESIDING IN CANADA TO REDUCE PENALTIES AND AVOID CRIMINAL PROSECUTION FOR PAST NON-COMPLIANCE WITH THE U.S….
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…
The May 21st edition of the National Post featured an article by Jamie Golombek discussing the harshness of the penalties for late-failing a T1135 Foreign Income Verification Statement;…
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…
According to an article in the February 16, 2011 Toronto Star, CRA has released an internal report which has highlighted deficiencies in its criminal enforcement division. …
According to an article published in the February 5, 2011 edition of the National Post, CRA has sent out questionnaires to high net worth Canadians regarding…
Swiss Accounts and Wikileaks According to an article in the January 19, 2011 edition of the Toronto Star, a former employee at Julius Baer – a…
Revoked Charities (Updated) The following is a list of the various charitable organizations or Registered Canadian Amateur Athletic Associations that have had their charitable registrations…
Alberta Court of Appeal finds inter-provincial tax planning not abusive under GAAR
Recently, the Alberta Court of Appeal released their decisions in Husky Energy Inc. v Alberta and Canada Safeway Limited v Alberta. The appeals addressed the…