Pages
Categories
Archives
Category Archives: Cases
The Gambler
The upsurge in interest in all things poker-related has sort of passed me by, like a lot of other trends and fashions. But, because I am a tax nerd, I have asked myself why it is that those who make … Continue reading
Posted in Cases, Individuals
Leave a comment
DIY Tax Planning Gone Wrong
It seems that, in S & D International Group Inc. v. Canada (Attorney General), 2011 ABQB 230, the court confronted a situation where the parties engaged in some do-it-yourself tax planning and, then, some do-it-yourself tax repair work. Fortunately for … Continue reading
Posted in Cases
Leave a comment
Privilege and a claim for legal expenses
In RICHARD A. KANAN CORPORATION v R, 2011 TCC 211, an informal procedure case, the Court was asked “how much information can the Minister, or the Court, require a taxpayer to produce in support of his or her expenses, if … Continue reading
Posted in Cases, Individuals
Leave a comment
Marechaux dismissed
The Supreme Court of Canada has dismissed the taxpayer’s application for leave to appeal from the decision of Federal Court of Appeal.
Posted in Cases, Charities and Not-for-Profits
Leave a comment
10-Year Limitation for Relief Revisited
In 2005, I wrote a post about the 10-year limitation period for relief applications that was introduced by the 2004 budget, and I noted that the drafting of the limitation period was ambiguous. The Federal Court of Appeal just released … Continue reading
Posted in Cases, CRA News
Leave a comment
The Savoy
Savoy v. The Queen, 2011 TCC 35, should be required reading for anyone called on to defend an individual from an assessment for unremitted source deductions.
Posted in Cases, Individuals
Leave a comment
More tax cases
I presented “Current Tax Cases” at the CRA’s quarterly Tax Practitioner’s Consultation Group meeting at the Royal Botanical Gardens on February 16. Please send an email to me (johnl att simpsonwigle.com) for a copy (our server is acting up and … Continue reading
Posted in Cases
Leave a comment
VD Case
A corporation withholds tax from a dividend that it pays to a non-resident and then fails to remit the amount withheld. The CRA later sends a letter to a shareholder of a shareholder of the dividend payor asking for information … Continue reading
Posted in Cases, Voluntary disclosures
Leave a comment
Childcare receipts
A casual reading of subsection 63(1) of the Income Tax Act suggests that a taxpayer claiming childcare expenses is required to produce receipts from the person providing the care. The subsection seems to permit the deduction of expenses “the payment … Continue reading
Posted in Cases, Individuals
Leave a comment
"Received"
In Morrison v. The Queen, 2010 TCC 429 (an informal procedure appeal), the individual taxpayers were employees of a corporation of which they were the controlling shareholders. The corporation purported to pay salary to the taxpayers by remitting amounts on … Continue reading
Posted in Cases, Individuals
Leave a comment