Articles

The Tax Court of Canada's recent decision in Noran West Developments Ltd. v. The Queen, where the Court quashed the appeal because the appellant had waived its right to object or appeal from the reassessment in issue.

Last year was busy for tax professionals with the introduction of complex legislative proposals and the long awaited omnibus technical amendment bills.

A recent decision from the Tax Court of Canada (the “Tax Court”) has affirmed the Canada Revenue Agency’s (“CRA”) position that player’s agent fees are non-deductible from a player’s salary.

A Ponzi scheme can be described as a scheme where a fraudster “robs Peter to pay Paul.”

Parliament recently decided to expand the legislation in s. 239 of the Income Tax Act to enable the CRA to punish tax advisors, promoters, planners and preparers.

The complexities of the deemed year end rules in the Income Tax Act were illustrated in a recent Technical Interpretation in which the CRA made some thought-provoking comments relating to a “sign and close” scenario.

Post mortem planning is any plan that can mitigate the amount of tax payable on the death of a taxpayer and in his or her estate.

A recent decision of the Tax Court of Canada denied a real estate developer’s claims for capital cost allowance on real estate development property held for sale but being rented prior to sale.

Twomey v. The Queen, addressed whether the taxpayer could claim the lifetime capital gains exemption on his sale of small business shares whether he held those shares for at least 24 months as required under the definition of “qualified small business corporation share.

The Tax Court of Canada recently released three related decisions involving the general anti-avoidance rule (GAAR) in section 245 of the Income Tax Act.