To many observers, the Federal Court’s November 2018 decision in Canada (National Revenue) v. Atlas Tube Canada ULC has tempered the enthusiasm that arose in the business community following the Federal Court of Appeal’s earlier ruling in BP Canada Energy Company v. Canada (National Revenue).
In a decision widely welcomed by lenders, the Supreme Court of Canada has ruled that the bankruptcy of a tax debtor, although subsequent to the repayment of the secured creditor’s debt, terminated secured creditors’ personal liability for deemed trust claims under s. 222 of the Excise Tax Act.
Should it hold up on appeal, the Tax Court of Canada’s September 2018 decision in Cameco Corporation v. The Queen may stand as one of the most resounding successes taxpayers have experienced to date in transfer pricing disputes with the Canada Revenue Agency.
With its denial of the Crown’s application for leave to appeal in Minister of National Revenue v. Iggillis Holdings Inc., et al., a tax case, the Supreme Court of Canada has restored normalcy to the law regarding common interest privilege, say lawyers.
LawPRO has missed out on an $83-million windfall after a judge denied the legal indemnity insurer’s claim for tax-exempt status.
Family lawyers say Canada’s outdated tax laws are penalizing former spouses who enter shared parenting arrangements for the care of their children.