Publications

Education and Tuition Tax Credits Revisited by Tax Court

Education and Tuition Tax Credits Revisited by Tax Court By: David M. Piccolo and Michael Thomson The Tax Court of Canada released its decision in…

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…

Deadlines to File Application for an Extension of Time

In a recent case from the Tax Court of Canada in Reynolds v The Queen 2013 TCC 288, the Court provided a simple reminder that…

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…

Hine v The Queen: settlement offers in “yes-no” cases

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

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,…

U.S. 2011 Offshore Voluntary Disclosure Initiative (2011 OVDI)

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….

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…

Foreign Reporting Penalties

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

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…

Tax Prosecutions

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. …