Search
Searching Content indexed under Trials & Appeals & Compensation by Timothy Fitzsimmons ordered by Published Date Descending.
Links to Result pages
 
1 2  
>>Next
 
Title
Country
Organisation
Author
Date
1
Fairmont: SCC Revises Common Law Test For Tax Rectifications
In a 7-2 decision in AG (Canada) v. Fairmont Hotels Inc, the Supreme Court of Canada has modified the common law test for rectification where the taxpayer has suffered an unintended and adverse tax result...
Canada
15 Dec 2016
2
SCC Rectification Decisions To Be Released On Friday December 9
The Supreme Court of Canada's decisions in two rectification cases, AG (Canada) v. Fairmont Hotels Inc. (Docket #36606)....
Canada
12 Dec 2016
3
Kruger: Appeal Allowed … Crown Awarded Costs
How should the Tax Court award costs where the taxpayer's appeal was allowed but no changes were made to the assessment at issue?
Canada
29 Jan 2016
4
Tax Court Establishes Motion Days In Toronto
The Tax Court of Canada has established a pilot project for regular motion days in Toronto for the period of February to September 2016. The Court will review the initiative in September 2016.
Canada
26 Jan 2016
5
NHL Team Denied Deduction For Road Meals?
We noticed these recent items regarding the U.S. IRS denial of a 100% deduction by the NHL Boston Bruins hockey club in respect of the team's provision of meals to employees during road trips.
Canada
26 Oct 2015
6
FCA Dismisses Appeal Of Revocation Of Charity Status
In Public Television Association of Quebec v. M.N.R. (2015 FCA 170), the Federal Court of Appeal dismissed the appeal by the Public Television Association of Quebec of the CRA's decision to revoke PTAQ's registered charity status.
Canada
4 Aug 2015
7
SCC Dismisses Appeal In Tax Advisor Penalty Case
The Supreme Court of Canada has dismissed the appeal of the taxpayer and determined that the tax advisor penalty in section 163.2 of the Income Tax Act is administrative in nature.
Canada
31 Jul 2015
8
SCC To Decide Tax Advisor Penalty Case On July 31
What is the nature of the third-party penalty in section 163.2 of the Income Tax Act? That question will be answered by the Supreme Court of Canada when it decides the case of Guindon v. The Queen.
Canada
29 Jul 2015
9
Zhang: BC SC Refuses To Rectify Share Transfer
The taxpayer was resident in British Columbia. He carried on a business of manufacturing and distributing laser equipment.
Canada
29 Jul 2015
10
Tax Court Continues "New Approach" To Cost Awards
The Tax Court's approach to cost awards has evolved significantly in recent years.
Canada
16 Jul 2015
11
New Judges Appointed To The Tax Court Of Canada And The Federal Court Of Appeal
A new judge has been appointed to the Tax Court of Canada.
Canada
29 Jun 2015
12
Fairmont: OCA Dismisses Crown's Appeal In Rectification Case
The Ontario Court of Appeal has dismissed the Crown's appeal in Fairmont Hotels Inc. v. A.G. (Canada) (2015 ONCA 441).
Canada
22 Jun 2015
13
Kruger: FX Derivatives Gains/Losses Taxed Only When Realized
In Kruger Incorporated v. The Queen (2015 TCC 119), the Tax Court held that the taxpayer could not value its foreign exchange options contracts on a mark-to-market basis, with the result that certain losses were not deductible by the taxpayer in a year.
Canada
11 Jun 2015
14
Mac's: Quebec CA Affirms Denial Of Rectification
Mac's, an Ontario corporation, was a wholly-owned subsidiary of Couche-Tard Inc. ("CTI"). In April 2005, Mac's borrowed $185 million from Sidel Corporation, a related Delaware corporation.
Canada
29 May 2015
15
Baytex: ABQB Grants Rectification
The Court determined that the requirements for rectification had been satisfied and thus granted the rectification of certain documents to accord with the parties' original intention.
Canada
27 May 2015
16
Ironside: TCC Orders Hearing Of Question On Rule 58 Motion
In Ironside v. The Queen (2015 TCC 116), the Tax Court allowed the Crown's Rule 58 motion for a determination of a question of law before the hearing.
Canada
21 May 2015
17
Loss Determinations: No Time Like The Present
Under subsection 152(1.1) of the Income Tax Act, a taxpayer may apply for a determination of losses for a tax year.
Canada
17 Apr 2015
18
Two New Judges Appointed To Tax Court Of Canada
Two new judges have been appointed to the Tax Court of Canada.
Canada
9 Feb 2015
19
Legge: Improper Pleading Fatal To Assessment
What must the Crown plead and how must she plead it? This question became an issue in the Tax Court's recent decision in Legge v. The Queen.
Canada
10 Dec 2014
20
McKesson: Additional Submissions On Motion
"The Order and Reasons for Recusal do not and should not form part of the record before this Court.
Canada
2 Dec 2014
Links to Result pages
 
1 2  
>>Next