How a CRA Tax Audit that uses Bank Deposit Analysis Affects Tax Reassessments in Canadian Tax Litigation: Comparing Premier Fasteners Inc. v The King and Hickman Motors Ltd. v Canada
The Tax Court of Canada decision in Premier Fasteners Inc.…
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Canadian Tax Litigation Insights: How the Jennings-Clyde (Vivatas, Inc.) Decision Protects Canadian Taxpayers’ Rights in Federal Court of Appeal
The recent Federal Court of Appeal ruling in Jennings-Clyde v.…
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Case Comment: How a Taxpayer’s Reliance on Frivolous Tax Appeals, Statute-Barred Tax Challenges in Court Backfired – Boucher v. Canada, 2004 FCA 46
Introduction The Federal Court of Appeal’s decision in Boucher v.…
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Agreements Must be in Writing: Hutchings v. The King (2025 TCC 108), a Case of COVID-19 Rent Subsidies
Canada Emergency Rent Subsidy Lessons: Verbal Agreements Left Businesses Without…
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Case Comment: Uppal Estate v. The King, 2024-816(IT)G upholds procedural fairness for Canadian taxpayers in tax litigation with the CRA, Tax Court
Introduction - Striking Tax Court Pleadings The Tax Court of…
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Case Commentary: Watts v The King, 2024 TCC 100 – Enhanced Costs of Litigation
In August 2024, the Tax Court of Canada delivered its…
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When Can the Federal Court Quash Abusive CRA Decisions to Assess Taxes: A Canadian Tax Lawyer Examines and Explains New 2024 Case Law
Introduction: Challenging CRA Decisions The Canada Revenue Agency (CRA), responsible…
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What Does Tax Court Decide? What Does Federal Court Decide? Supreme Court Clarifies Jurisdictions Through Recent Cases: Dow Chemical and Iris Technologies
Introduction On June 28, 2024, the Supreme Court released its…
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When Can Discovery Answers of a Deceased Canadian be Used Under Subsections 100(6)-(7) of the Tax Court of Canada Rules?
Introduction – Use of Deceased Examinee’s Answer’s in a Tax…
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Case Commentary: Paquet c. Le Roi – Reversing the Burden of Proof from the Taxpayer to Canada Revenue Agency (CRA)
Introduction: Disproving the Inclusion of Income by the CRA In…
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