Articles

The taxpayer in Academy of Applied Pharmaceutical Sciences v. R. relied on representations of an auditor regarding a method for properly allocating between GST/HST exempt and non-exempt services. At issue, therefore, was the application of the doctrines of estoppel and officially induced error.

The article: (i) provides an overview of Canada Revenue Agency’s voluntary disclosure program; and (ii) highlights certain recent changes regarding the administration of the program.

The article provides an overview of new legislation that requires all international electronic funds transfers of $10,000 or more to be reported to the Canada Revenue Agency.

The Supreme Court's recent decision in AES/Riopel makes clear that a remedy similar to common law rectification is available in Quebec. Although the case focuses on the civil law, it also provides both comfort and a list of caveats for taxpayers in the common law provinces.

The Federal Court of Appeal recently released reasons for this case. The detailed judgment reviews the instances in which a taxpayer may bring an application for judicial review of CRA actions before the Federal Court.

The recent decision in Piersanti v. The Queen offers an important lesson for both tax professionals and criminal defence counsel: taxpayers who do not challenge the admissibility of evidence risk having that evidence used against them in subsequent civil tax proceedings.

A summary of the Tax Court Chief Justice's address to the attendees of the 2013 Canadian Tax Foundation national conference.

In a recent Tax Court of Canada ruling on a motion heard in Imperial Tobacco Canada Limited v. The Queenthe Court considered a motion for an Order directing the Appellant to attend and be cross-examined on its List of Documents...

In Bakorp Management Ltd. v. The Queen, the Tax Court of Canada granted the Crown’s motion for dismissal of the appeal. 

A recent decision of the Tax Court of Canada, NRT Technology Corp. v. R, confirms the use of the reasonable expectation of profit test in the context of subsection 111(5)of the Income Tax Act (Canada).