An important decision from the tax court says the CRA must meet the criminal burden of proof under s. 163.2
Genuine sales to a trust by its beneficiaries are not subject to the attribution rules
A cluster of recent judgments sheds light on developments in tax planning using trusts and private corporations
The Tax Court has ruled that the innocent beneficiary of a Ponzi scheme does not owe taxes on her winnings
Recent, similar challenges by the CRA lead to mixed results
One proposal would raise the monetary limit for pursuing a tax appeal using an informal procedure from $12,000 to $25,000
Major law firms are participating in new pro bono programs to assist litigants at the OSC and the Tax Court of Canada
Clients may need special guidance when using the Homebuyers’ Plan to make several staged deposits for unbuilt homes
Two decisions from the Tax Court of Canada appear to limit the effect of the CRA’s own interpretation bulletin (IE:TV)
Key decision-making by a foreign trustee will play a crucial role in tax treatment