Loyalty point programs demonstrate that, for GST/HST purposes, a payment can be received in its entirety as both a commercial and exempt amount. The Federal Court of Appeal (“FCA”) recently...
Questions on tax jurisdiction currently cause headaches for many taxpayers attempting to resolve a tax issue. It can be difficult to determine whether the Tax Court of Canada (“TCC”) or...
In Deans Knight Income Corp. v Canada, 2023 SCC 16, (“Deans Knight”) the Supreme Court of Canada (“SCC” or “the Court”) dismissed the taxpayer’s appeal, holding that the General Anti-Avoidance...
Introduction The Supreme Court of Canada (“SCC”) bifurcated 8-1 in Canada (Attorney General) v Collins Family Trust, 2022 SCC 26 (“Collins”) with Brown J writing for the majority and Côté...
