R. v. Fairmont Hotels - SCC: Leave granted in Ontario rectification case

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Attorney General of Canada v. Fairmont Hotels Inc., et al. (December 10, 2015 – 2015 SCR 36606, Cromwell, Wagner and Côté JJ.).

Précis: The Supreme Court of Canada has granted leave to appeal from a decision of the Ontario Court of Appeal blogged earlier on this site (2015 ONCA 441). No reasons were issued.

This sets the stage for a potentially very significant review by the Supreme Court of Canada of the entire area of rectification in tax cases since on November 19 the Court granted leave in a tax rectification case coming out of Québec: Jean Coutu Group (PJC) Inc. v. Attorney General of Canada (SCC 36505).

About the Author

Bill Innes

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William (Bill) Innes has practiced in the areas of tax litigation, taxation and estates and trusts since 1975. His practice includes all aspects of dispute resolution in taxation matters under both federal and provincial legislation, but with a special emphasis on appeals under the Income Tax Act (Canada). In addition, Bill acts as counsel in matters of estate and trust law and serves as an advisor to large charitable and non-profit institutions on issues of trusts, estates and taxation. He frequently appears as counsel before the Tax Court of Canada, the Federal Court and the Federal Court of Appeal.

For advice on tax litigation matters contact Bill:

WILLIAM I. INNES

email: william.innes@williaminnes.ca
416-869-2204
www.williaminnes.ca

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Bill is listed and recognized in the 2020 edition of Best Lawyers in Canada; Lexpert/ROB Special Edition 2020 – Canada’s Leading Litigation Lawyers; 2020 Canadian Legal Lexpert Directory - Consistently Recommended - Litigation - Corporate Tax; and Canadian Who’s Who.

Bill is also AV Peer and Judicial Review Rated according to Martindale-Hubbell (Preeminent), its highest level of professional ranking.

Bill is a member of the Editorial Boards of the Canadian Tax Journal and Tax Litigation and a past member of the Editorial Boards of the CCH Canadian Tax Reporter and the CCH Annotated Income Tax Act.

Bill is the author or co-author of several legal texts and numerous articles, including:

Tax Evasion, William I. Innes. (Scarborough, Ont.: Carswell, 1995 - Looseleaf).

The essential GAAR manual: policies, principles and procedures. William I. Innes, Patrick J. Boyle, Joel A. Nitikman. (Toronto: CCH Canadian, 2006).
Charities, non-profits and philanthropy under the Income Tax Act, William I. Innes, Patrick J. Boyle. (Toronto: CCH Canadian: Fraser Milner Casgrain, 2006).
Federal tax practice, William Innes & Brendan Bissell, (Toronto: CCH Canadian, 2007).

Bill was a member of the International Academy of Estate and Trust Law from 1992 to 2012.

R. v. Fairmont Hotels - SCC: Leave granted in Ontario rectification case

About the Author

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