Equity Cannot Relieve Tax Mistakes
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...
Tagged: equity
Discord and the Sword: An Estate Dispute and Proprietary Estoppel in Cowper-Smith v Morgan
In Cowper-Smith v Morgan, 2017 SCC 61 [Cowper-Smith], the Supreme Court of Canada (“the Court”) brings back painful memories of first-year Contracts and attempts to clarify the complex equitable doctrine of...
Rectification is Not Equity’s Mulligan: New Insights on the Law of Rectification in Tax Liability
The Supreme Court of Canada (“SCC”) has recently delivered two companion judgments, Canada (Attorney General) v Fairmont Hotels Inc., 2016 SCC 56 [Fairmont] and Jean Coutu Group (PJC) Inc. v Canada (Attorney...
