On November 14, 2019, the Supreme Court of Canada denied the taxpayer's application for leave to appeal from judgment of the Federal Court of Appeal in Birchcliff Energy Ltd. v The Queen, 2019 FCA 151.
The Tax Court of Canada recently released Practice Note No. 22 entitled "Experts' Panel (Hot Tubbing)" (Protocol).
With
Robyn Gurofsky,
Lisa Hiebert,
Braek Urquhart
On November 8, 2018, in a decision delivered unanimously from the bench, the Supreme Court of Canada confirmed that the Crown's superpriority over unremitted Goods and Services Tax/Harmonized Sales Tax (GST/HST) is ineffective against a secured creditor who received, prior to a tax debtor's bankruptcy, proceeds from that taxpayer's assets.
With
Bhuvana Sankaranarayanan
Canada (National Revenue) v Atlas Tube Canada ULC1 is the latest in a series of cases considering the ability of the Canada Revenue Agency (CRA) to compel corporate disclosure of confidential reports analyzing the tax positions of a company.
With
Bhuvana Sankaranarayanan
Canada (National Revenue) v Atlas Tube Canada ULC1 is the latest in a series of cases considering the ability of the CRA to compel corporate disclosure of confidential reports analyzing the tax positions of a company.
With
Nadia Effendi,
Steve Suarez
Iggillis Holdings Inc. and Ian Gillis v. Minister of National Revenue, 2018 FCA 51
With
Shannon James
On June 25, 2018, the Federal Court of Appeal upheld the 2016 decision of the Tax Court of Canada in Rio Tinto Alcan Inc. v. The Queen1 that investment banking and professional advisory fees incurred
With
Robyn Gurofsky,
Lisa Hiebert,
Braek Urquhart
On March 22, 2018, the Supreme Court of Canada granted leave to appeal in Canada v Callidus Capital Corporation1 ("Callidus"), meaning the extent of the post-bankruptcy superpriority ...
With
Nadia Effendi,
Shannon James,
Alessandra Nosko
A collective sigh of relief reverberated across the tax and corporate law bar when, on March 6, 2018, the Federal Court of Appeal released its reasons in Iggillis Holdings Inc. v Canada...
With
Shannon James
On December 15, 2017, the Canada Revenue Agency ("CRA") released two highly-anticipated policy statements outlining several changes to its Voluntary Disclosures Program (the "VDP").
With
Shannon James
On December 15, 2017, the Canada Revenue Agency ("CRA") released two highly-anticipated policy statements outlining several changes to its Voluntary Disclosures Program (the "VDP").
With
Shannon James
The decision of the Court is the latest in a line of authority severely restricting the ability of parties to correct mistakes through rectification.
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