1074022 B.C. Ltd. v. Li – Misinterpretation of Section 116 of the Income Tax Act and the Need for Legislative Reform

The Legal Background & CRA’s Section 116 Collection Powers The CRA is obligated to apply…

Published: April 30, 2020

Last Updated: October 25, 2021

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White v. The Queen – Derivative Liability for Income Tax and GST/HST – Toronto Tax Lawyer Analysis

Introduction – Derivative Liability for Income Tax and GST/HST The Canada Revenue Agency (CRA) has…

Published: April 30, 2020

Last Updated: May 20, 2020

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Suing the Canadian Revenue Agency for Negligence

The Case of Gordon v Queen and the existence of a duty of care In…

Published: April 30, 2020

Last Updated: August 24, 2021

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Taxation of Shareholders: The Basic Deemed-Dividend Tax Rules—A Canadian Tax Lawyer’s Analysis

Introduction – The What And Why of a Deemed Dividend What is a deemed dividend?…

Published: April 30, 2020

Last Updated: February 21, 2022

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The Tax Court of Canada Tests a New Procedure – The Preliminary Ruling Docket: Canadian Tax Lawyer Analysis

Introduction: Tax Court Deals with Increasing Backlog With the rise of the internet and the…

Published: April 30, 2020

Last Updated: July 17, 2020

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Deadlines for Notice of Objections, Notice of Appeals, and Extension of Times – Canadian Tax Lawyer Explains

Tax Notices of Objection, Deadlines and Applying for Extensions Upon receiving a Notice of Assessment…

Published: April 30, 2020

Last Updated: April 26, 2021

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CHR Investment Corporation v The Queen – GAAR – (Subsection 245(2)) of the Income Tax Act and the Need for Clarify on Policy Application and Analysis

The Legal Background & Section 245’s GAAR Policies The general anti-avoidance rule (“GAAR”) is found…

Published: April 30, 2020

Last Updated: October 25, 2021

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Can the CRA Pursue the Beneficiary of Your Life Insurance Under Section 160 of the Income Tax Act? A Canadian Tax Lawyer’s Analysis

Introduction: Derivative Tax Liability & Life-Insurance Beneficiaries Section 160 of the Income Tax Act broadens…

Published: April 30, 2020

Last Updated: May 20, 2020

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A Canadian Tax Lawyer’s Introduction to Tax Filing for International Students

Welcome to Canada’s Tax System Tax season can be especially confusing for international students who…

Published: April 30, 2020

Last Updated: October 21, 2022

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