Recent Posts

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  Quinco Financial Inc. v. R. – FCA: Interest on a GAAR assessment commences to run on the balance-due date for taxation year involved, not the date the GAAR assessment is issued

  Aug 02, 2018 By Bill Innes

  Categories:

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

  Précis: The taxpayer argued unsuccessfully in the Tax Court that interest on a GAAR assessment should not commence to run until the date of the issuance of the assessment. The taxpayer appealed to the Federal Court of Appeal which dismissed the appeal with costs.
  Quinco Financial Inc. v. R. – FCA: Interest on a GAAR assessment commences to run on the balance-due date for taxation year involved, not the date the GAAR assessment is issuedREAD MORE »
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  Quinco Financial Inc. v. R. - TCC: Interest on GAAR assessment not limited to period after assessment

  Oct 05, 2016 By Bill Innes

  Categories:

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

  Précis: In J.K. Read Engingeering Ltd. v. The Queen (October 21, 2014 – 2014 TCC 309, Hogan J.), a case blogged earlier on this site, the Tax Court held that in the case of a GAAR assessment interest ran from the payment date for the taxation year being assessed not from the date of the assessment. The taxpayer in this case took another run at the issue asking the Court to revisit the matter in an application on a point of law under section 58 of the Tax Court of Canada Rules (General Procedure). It came as no great surprise that the taxpayer’s submissions were again rejected.
  Quinco Financial Inc. v. R. - TCC: Interest on GAAR assessment not limited to period after assessmentREAD MORE »
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  J.K. Read Engineering Ltd. – TCC: Interest on GAAR assessment starts to run when tax incurred, not when GAAR assessed

  Oct 29, 2014 By Bill Innes

  Categories:

  • Bill Innes on Current Tax Cases
  • Corporate Tax
  • Employment Insurance/CPP
  • Federal Income Tax

  
  J.K. Read Engineering Ltd. – TCC: Interest on GAAR assessment starts to run when tax incurred, not when GAAR assessedREAD MORE »