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)
The Tax Court of Canada overturned more than $20 million…
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What Is the Standard of Review for Discretionary Decisions of the CRA Appealed to the Federal Courts? A Canadian Tax Lawyer Explains
Overview Discretionary Decisions Are Appealed to the Federal Courts, Not…
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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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