Antle v. Canada, 2010 FCA 280 – Sham Trust
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
CRA Section 160: How to fight a Section 160 Assessment
CRA Section 160: Liable for Their Taxes
Section 160 of the Income Tax Act and section 325 of the Excise Tax Act are often used by the Canada Revenue Agency to affix liability for tax to recipients of transfers from persons with tax debts. Accordingly, if someone transfers something of value to you, while they...
CRA Audits and Oral Interviews
Cameco - Can CRA force a Taxpayer to attend an In-Person Oral Interview during a CRA Audit?
NOTE: 2021 Federal Budget change nullifies this decision…
Canada (National Revenue) v. Cameco Corporation, 2019 FCA 67 (CanLII)
In Cameco, the Federal Court of Appeal...