The GAAR applied: Deans Knight Income Corp v Canada
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...
Tagged: income tax act
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...
Jurisdiction Confusion: The SCC to Clarify the Federal and Tax Courts’ Roles in Taxation Law in Dow Chemical Canada
The Supreme Court of Canada (“SCC”) will soon comment on the jurisdictional contours of the Tax Court of Canada (“TCC”) and Federal Court of Canada (“FCC”). The SCC has granted...
Clash of the Interpretative Titans: Canada v. Canada North Group Inc.
In Canada v. Canada North Group Inc., 2021 SCC 30 [Canada v CNG], the Supreme Court of Canada (“SCC”) considered whether courts can order a super-priority charge that takes primacy...
