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Searching Content indexed under Trials & Appeals & Compensation by Rotfleisch & Samulovitch P.C. ordered by Published Date Descending.
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1
Case Comment – Glatt v Canada (National Revenue) ("Glatt")
Under the Income Tax Act, RSC 1985, c 1 (5th Supp) ("ITA") 164(3) the CRA must refund interest at a prescribed rate based on the amount in respect of a taxation year that is refunded or repaid.
Canada
20 Aug 2019
2
Gordon Et Al v The Queen – Canadian Tax Lawyer's Analysis And Comments
The plaintiffs, Allan Jay Gordon, James A. Deacur and Associates Ltd. [and James Allan Deacur sought damages from the government of Canada alleging that the Canada Revenue Agency conducted tortious act in its criminal investigation.
Canada
6 Aug 2019
3
Case Comment – MNR v Roofmart Ontario Inc. ("Roofmart")
The CRA has general powers to require persons to provide information related to a tax audit however these general powers are limited, such that, the CRA cannot require persons to provide third party documents without judicial authorization.
Canada
4 Jul 2019
4
Henson Trusts: Supreme Court Clarifies And Approves
A Henson trust is a type of trust that is settled for the purpose of benefitting a person with disabilities.
Canada
4 Jul 2019
5
Self-Represented Taxpayer Has Case Dismissed Before Hearing At Federal Court Of Canada – Canadian Tax Lawyer's Analysis And Comments
Lawrence Franklin Glazer recently had his Action against the CRA dismissed on a summary judgement.
Canada
18 Jun 2019
6
Supreme Court Of Canada Endorses The Federal Court Of Appeal's Denial Of GST/HST New Housing Rebate Where A Bare Trustee Takes Title – Application For Leave To Appeal Denied: Cheema v The Queen, 2019 Canlii 10518
On February 14, 2019, the Supreme Court of Canada dismissed the taxpayer's application for leave (permission) to appeal the Federal Court of Appeal's split decision in The Queen v Cheema (2018 FCA 45).
Canada
14 Mar 2019
7
Crean v Canada - Rectification Article
Rectification gives parties a means of fixing mistakes in a written agreement or other legal document.
Canada
6 Mar 2019
8
405 Canada Inc v MNR
The CRA must, however, exercise this discretionary authority in a manner that is fair—both procedurally and substantively.
Canada
31 Jan 2019
9
Net-Worth Tax Assessments And The Onus Of Proof In Tax Cases: Toronto Tax Lawyer Case Review - Truong v The Queen, 2017 TCC 22
On October 18, 2018 the Supreme Court of Canada summarily dismissed an Appeal from the Federal Court of Appeal without reasons, as per its standard practice.
Canada
31 Oct 2018
10
B.C. Court Grants Rectification For A Corporation's Incorrectly Calculated Capital Dividend Account Balance
The case involved 551928 Manitoba Ltd. ("the Corporation"), which hired accountants to estimate its full capital dividend account balance.
Canada
21 Sep 2018
11
Do Transfers To Agents Invoke Vicarious Tax Liability Under Section 160? A Canadian Tax Lawyer's Analysis
Section 160 of the Income Tax Act is a tax collection tool. It thwarts a taxpayer's attempts at moving money beyond the tax collector's reach by placing it in presumably friendly hands.
Canada
18 Sep 2018
12
Multiple Taxpayers Successfully Sue The CRA For Damages In Negligence: Ludmer et al c. Attorney General Of Canada
The facts and a detailed analysis by our skilled Canadian tax lawyers follows on this watershed case.
Canada
23 Aug 2018
13
Sarmadi v. Canada — Credibility In Tax Law Cases — A Canadian Tax Lawyer Analysis
In Sarmadi v. Canada, 2017 FCA 131, the appellant taxpayer appealed to the Federal Court of Appeal from the decision of the Tax Court of Canada to deny his appeal.
Canada
30 Nov 2017
14
Tax Avoidance & Tax Planning – General Anti-Avoidance Rule – Canadian Tax Lawyer Analysis
The line between effective tax planning and tax avoidance is not always a bright one. In fact, taxpayers may find themselves in the crosshairs of the CRA even if they have complied with the letter of the law.
Canada
25 Sep 2017
15
CRA's Power To Compel Information Protected Under Solicitor-Client Privilege — Canadian Tax Lawyer Analysis
Legal privilege protects information from disclosure. That is, if your conversation with another person qualifies as privileged, that person cannot be compelled to reveal the contents of that conversation.
Canada
27 Jul 2017
16
Anderson v. Benson Trithardt Noren LLP –Update On Tax Rectification – Toronto Tax Lawyer Case Comment
Rectification is a remedy that can be sought when a legal document fails to reflect the intent of the parties to that document.
Canada
13 Apr 2017
17
SCC Update On Tax Rectification
Part III of this Toronto tax lawyer tax rectification article discusses the Supreme Court of Canada's decision and its tax planning implications.
Canada
8 Mar 2017
18
Canada (Attorney General) v. Fairmont Hotels Inc. – SCC Update on Tax Rectification – Toronto Tax Lawyer Analysis - Part II
Part I of this article provided background on the doctrine of rectification and how it is used in the Canadian tax context.
Canada
27 Feb 2017
19
Canada (Attorney General) v. Fairmont Hotels Inc. – SCC Update on Tax Rectification – Toronto Tax Lawyer Analysis - Part I
Tax rectification is a remedy that can be sought when a legal document fails to reflect the tax intent of the parties to that document.
Canada
27 Feb 2017
20
Supreme Court Rectification Decision In Farimount Hotels
Rectification is an equitable doctrine that is applicable in situations where parties have agreed on terms of a contract that due to inadvertence is not reflected in their written agreement.
Canada
6 Jan 2017
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