What Is the Standard of Review for Discretionary Decisions of the CRA Appealed to the Federal Courts? A Canadian Tax Lawyer Explains
Introdction The Canada Revenue Agency (“CRA”) is an administrative body…
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A Canadian Tax Lawyer’s Guide to Canada Emergency Wage Subsidy Claims Audits and Appeals
Introduction: The Canada Emergency Wage Subsidy (CEWS) The Canada Emergency…
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When Is it Worth Challenging the CRA’s Defective Tax-Court Pleadings? Reconciling the Federal Court of Appeal’s decisions in Preston and Adboss
Lessons for Canadian Taxpayers in Tax Litigation Introduction: The Canada…
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Taxpayers must articulate reasons for not responding to questions in motions in Tax Court – Richard Quigley v The King: Powers of CRA Series
Discovery is part of the process in most litigation including…
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Canadian Taxpayers, Beware: The CRA Gets Away with Defective Pleadings During Tax Litigation
Introduction: Canada v. Preston, 2023 FCA 178 For the most…
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How not to Screw up Applying for an Extension of Time when Filing a Notice of Objection to a Re-assessment by CRA: DiPierdomenico v. The King
Introduction: Extension of Time Applications The Canada Revenue Agency regularly…
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Fighting with CRA? Pick the Right Forum for Tax Disputes: Federal Court or Tax Court that has Jurisdiction
The Federal Court of Appeal decision in Canada (Attorney General)…
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Preston Family Trust II v The Queen: Guidance from a Canadian Tax Lawyer Regarding Assumptions of Facts in Replies to a Notice of Appeal
Taxpayers filed motions to strike out CRA’s assumptions in its…
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Matthew Macisaac Consulting Inc. v Her Majesty the Queen – Guidance on Tax Court General Procedural Rule 58 from a Canadian Tax Lawyer
Introduction - Taxpayer filed motion for determination under rule 58…
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Tax Litigants May Amend Their Arguments During a Trial – A Toronto Tax Lawyer Analysis of The Queen v Pomeroy Acquireco Ltd
Introduction – Amending Replies During Tax Litigation In the course…
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