In Yao v. The Queen, 2022 TCC 23 (CanLII) [Yao], the primary issue was whether certain expert reports were admissible into evidence. The related tax aspect triggering the dispute is the question of the Appellants’ eligibility for the Canada Child
CRA Audits of Canadian Sales to Foreign Entities Agent-Principal and CRA GST/HST Audit CRA audits have targeted Canadian sales to foreign entities. As a result, Canadian entities are denied GST/HST Input Tax Credits (“ITC”) based on an assumed agency/agent relationship
The Federal Court of Appeal, in Antle v Canada, 2010 FCA 280, upheld the Tax Court of Canada decision in Antle v. The Queen, 2009 TCC 465, finding that an offshore spousal trust was not valid…Read More
Limited Partnership Tax Shelters & At-Risk Rules What are the At-Risk Rules? The at-risk amount rules (at-risk rules) are used by Canada Revenue Agency (“CRA”) to counter the abusive deduction of partnership losses. Limited partnerships are commonly utilized in tax
In Chan v. The Queen 2022 TCC 87 [Chan], a decision under the Tax Court of Canada’s informal procedure, the primary issue was the beneficial ownership of specified foreign property (a bank account allegedly containing illegally procured funds) and the
CRA can Compel Oral Interviews – Cameco – 2021 Federal Budget Oral Interviews, CRA Audits and the Cameco Decision In did not take long for the Federal government to nullify the decision in Canada (National Revenue) v. Cameco Corporation, 2019