Further thoughts on the Fundy Settlement decision: Supreme Court offers a...
In Garron Family Trust v. The Queen (2009 TCC 450), Justice Judith Woods of the Tax Court of Canada came down with a very broad new rule for determining the residence of trusts. [162] I conclude,...
View ArticleCRA Provides Update on Audit Priorities and Activities
At the Canadian Tax Foundation’s recent Ontario Tax Conference (October 29-30), the Canada Revenue Agency provided an update on its current audit priorities and activities as part of the conference’s...
View ArticleFCA Dismisses Lord Black’s Tax Appeal
Earlier this year, in Black v. HMQ (2014 TCC 12), Lord Conrad Black unsuccessfully argued in the Tax Court of Canada that, due to his U.K. residency status, he should not be subject to Canadian tax on...
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