Recent Posts

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  Kinglon Investments Inc. v. R. - FCA: CRA need not plead person for whom tax shelter representations made

  Jun 03, 2015 By Bill Innes

  Categories:

  • Bill Innes on Current Tax Cases
  • Corporate Tax
  • Federal Income Tax

  Précis: This case involved what the Crown alleged to be an unregistered tax shelter. Part of the Crown’s Reply dealt with statements allegedly made concerning the tax shelter.
  Kinglon Investments Inc. v. R. - FCA: CRA need not plead person for whom tax shelter representations madeREAD MORE »
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  Levin v. R. - TCC: Taxpayer not entitled to Canada Child Tax Benefit - children did not reside with him

  May 23, 2015 By Bill Innes

  Categories:

  • Bill Innes on Current Tax Cases
  • Personal Tax, Estate & Wealth Planning

  Précis: Mr. Levin and his former spouse had three children. In 2001 they agreed to joint custody with Mr. Levin having the children 6 days in every 14. This appeal concerned his claim to the Canada Child Tax Benefit (the “Benefit”) for the 2009, 2010 and 2011 base years (he dropped his claim in respect of the 2012 base year).
  Levin v. R. - TCC: Taxpayer not entitled to Canada Child Tax Benefit - children did not reside with himREAD MORE »
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  Ironside v. R. - TCC: Court orders hearing whether decision in prior tax years gives rise to issue estoppel - Rule 58

  May 21, 2015 By Bill Innes

  Categories:

  • Bill Innes on Current Tax Cases
  • Personal Tax, Estate & Wealth Planning

  Précis: In 2013 the Tax Court reached a decision dismissing Mr. Ironside’s appeal concerning the deduction in 2003 and 2004 (and resulting losses applied to 2002 and 2006) of legal and other professional fees to defend himself against allegations of committing improper disclosures after being charged in June of 2001 by the Alberta Securities Commission.
  Ironside v. R. - TCC: Court orders hearing whether decision in prior tax years gives rise to issue estoppel - Rule 58READ MORE »
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  R. v. Revcon - FCt: Taxpayer has limited success asserting solicitor-client privilege in requirement case

  May 06, 2015 By Bill Innes

  Categories:

  • Bill Innes on Current Tax Cases
  • Federal Income Tax
  • Other

  Précis: In 2013 CRA issued two requirements to Revcon Oilfield Constructors Incorporated (“Revcon”) for information requiring the taxpayer to produce materials in connection with a reorganization it undertook in 2011.
  R. v. Revcon - FCt: Taxpayer has limited success asserting solicitor-client privilege in requirement caseREAD MORE »
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  Fiorucci v. R. – FCt: CRA reasonable in refusing to allow loss where no documentation provided by taxpayer

  Mar 03, 2015 By Bill Innes

  Categories:

  • Bill Innes on Current Tax Cases
  • Other

  
  Fiorucci v. R. – FCt: CRA reasonable in refusing to allow loss where no documentation provided by taxpayerREAD MORE »