Tax Litigation & Tax Dispute Resolution Insights

Image for Budget 2024 grants CRA expansive new audit powers

Budget 2024 grants CRA expansive new audit powers

Insight

Published: July 12, 2024

Authors: Nicholas Horlick, Kurt Wintermute, K.C.

Categories: Tax Litigation & Tax Dispute Resolution, Taxation

This article was prepared with the assistance of MLT Aikins Summer Student Sam Riendeau. The federal government tabled its most recent budget on April 16, 2024 (“Budget 2024”). It includes a … Read More

Image for Rectification in the tax context: Quebec Court of Appeal gives hope to a damaged equitable remedy

Rectification in the tax context: Quebec Court of Appeal gives hope to a damaged equitable remedy

Insight

Published: June 28, 2023

Author: John Agioritis

Categories: Tax Litigation & Tax Dispute Resolution, Taxation

This article was prepared with the assistance of summer law student Brooke Healey. Documenting your intentions in a tax plan is crucial if you ever pursue rectification as an equitable remedy, … Read More

Image for Taxpayer successfully appeals gross negligence penalties

Taxpayer successfully appeals gross negligence penalties

Insight

Published: June 6, 2023

Author: John Agioritis

Categories: Tax Litigation & Tax Dispute Resolution, Taxation

This article was prepared with the assistance of summer student Cole Shrimpton. The Tax Court of Canada has found that an international businessman who hired lawyers and accountants to organize his … Read More

Image for Saskatchewan Court of Appeal Reinforces Importance of Comparability in Assessment

Saskatchewan Court of Appeal Reinforces Importance of Comparability in Assessment

Insight

Published: March 30, 2022

Authors: Nicholas Horlick, Kurt Wintermute, K.C.

Categories: Tax Litigation & Tax Dispute Resolution

CP Reit S Real Estate Limited v Saskatoon (City), 2021 SKCA 100 was an appeal of a group of commercial properties including grocery stores, restaurants, drug stores, salons, a movie … Read More

Image for Federal Court of Appeal Reverses Tax Court Decision on Cascading Derivative Assessments and Preconditions to Liability Under Section 160 and 227.1 of the Income Tax Act

Federal Court of Appeal Reverses Tax Court Decision on Cascading Derivative Assessments and Preconditions to Liability Under Section 160 and 227.1 of the Income Tax Act

Insight

Published: September 25, 2020

Authors: John Agioritis, Nicholas Horlick

Categories: Tax Litigation & Tax Dispute Resolution, Taxation

Authors: John Agioritis, Nicholas Horlick, Justin Di Liello In the recent decision of Her Majesty the Queen v Colitto, 2020 FCA 70 (“Colitto”), the Federal Court of Appeal (the “FCA”) unanimously … Read More