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Searching Content indexed under Income Tax by Timothy Fitzsimmons ordered by Published Date Descending.
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1
Correcting Tax Mistakes After Fairmont And Jean Coutu
I was very glad to be a panelist for the Canadian Tax Foundation's conference on the Supreme Court of Canada's decisions in Fairmont and Jean Coutu.
Canada
2 Mar 2017
2
506913 N.B. Ltd.: Jarndyce V. Jarndyce Revisited
On a procedural motion in 506913 N.B. Ltd. v. The Queen (2016 TCC 286), the Tax Court ordered the Respondent to answer all questions refused on discovery,
Canada
4 Jan 2017
3
Auditor General Provides Recommendations For Improving CRA Review Of Objections
Under the federal Income Tax Act, the Canada Revenue Agency must consider a taxpayer's objection and must vacate, confirm or vary the underlying tax assessment.
Canada
1 Dec 2016
4
Tax Court Introduces Common Books Of Authorities Project
Tax Court has implemented a new common books of authorities program for its Toronto courtrooms that will eliminate the need for taxpayers to print copies of certain frequently-cited authorities.
Canada
14 Apr 2016
5
CRA: Drones Depreciable At 25%
Aerial drones appear to have many commercial uses. If you use a drone in your business, you may be able to deduct capital cost allowance in respect of the drone.
Canada
7 Apr 2016
6
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
7
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
8
Beware Of Telephone Tax Scams
Several clients have contacted me in recent weeks after receiving telephone calls from individuals who claim to be from the Canada Revenue Agency.
Canada
17 Aug 2015
9
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
10
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
11
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
12
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
13
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
14
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
15
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
16
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
17
McKesson: Taxpayer Files Supplementary Factum
As expected, the taxpayer has filed a Supplementary Memorandum of Fact and Law in its transfer pricing appeal in the Federal Court of Appeal.
Canada
8 Jan 2015
18
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
19
Guindon: SCC Hears Arguments In Penalty Case
The Supreme Court of Canada heard oral arguments today in the case of Guindon v. The Queen. At issue in the case is the nature of the third-party penalty in section 163.2 of the Income Tax Act.
Canada
9 Dec 2014
20
Brogan Family Trust: CRA Not Entitled To Notice Of Rectification Application
Is the CRA entitled to notice of a rectification application?
Canada
14 Nov 2014
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