Cancelled Arrears Interest Reduces Tax liability for Transferor & Transferee

Scott v The Queen - Cancelled Arrears Interest Reduces the Tax liability of both Transferor…

Published: May 12, 2020

Last Updated: October 25, 2021

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Estate Planning & Tax Planning During the Coronavirus (COVID-19) Pandemic – A Canadian Tax Lawyer’s Guide

Introduction – COVID-19 & Your Estate, Your Inheritance, and Your Taxes Ripping through the world’s…

Published: May 8, 2020

Last Updated: September 13, 2021

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The Case of Scott v Queen and the Importance of Evidence: A Canadian Tax Lawyer’s Perspective

In the recent case of Scott v Queen 2020 TCC 4, the Tax Court of…

Published: May 1, 2020

Last Updated: May 20, 2020

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U.S. Profits Interests: What Are They & How Are They Taxed in Canada?—A Canadian Tax Lawyer’s Analysis

Introduction – U.S. Profits Interests For U.S. federal income-tax purposes, one may hold one of…

Published: May 1, 2020

Last Updated: October 8, 2020

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Gordon et al v The Queen – Canadian Tax Lawyer’s Analysis and Comments

Introduction: CRA has the power to conduct investigation on account of misrepresentations The plaintiffs, Allan…

Published: May 1, 2020

Last Updated: August 24, 2021

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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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