Tax Law Blog

Admissibility of Expert Evidence in Tax Court

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

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Agent-Principal Relationships and GST/HST Audits

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

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At-Risk Amount Rules & Partnerships

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

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Budget 2021: CRA can Compel Oral Interviews

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

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