The taxpayer was assessed shareholder benefits because BBH Ltd. (of which he was also a direct shareholder) paid premiums in respect of insurance policies that insured his life and that of his spouse and for which the beneficiaries were his spouse and stepchildren.
Wilful Blindness to Bad Tax Advice
The taxpayer was a contractor who was in business for over 25 years. He then started to attend meetings from Paradigm Education Group after talking to a friend. Unbeknown to him, his life was about to take a turn for the worse.
Lending Activity Did Not Possess the Positive Indicia of a “Business”
The appellant was a businessman who made his fortune in the oil and gas industry. In order to fructify his capital, he decided to lend money to third parties. When two companies to which he lent money went bankrupt, he claimed business losses in relation to the loans he made to these two companies.
Don’t Count on a Remission Order
The Andertons (husband and wife) brought two applications for judicial review after the Director General of the Legislative Policy Directorate and Legislative Affairs Branch of the Canada Revenue Agency (the “Director General”) refused to recommend a remission of their tax debts (which included income taxes, interests and penalties).
Question de raisonnabilité
L’arrêt Gervais Auto Inc. c. Agence du revenu du Québec est intéressant parce qu’il revient sur le fardeau de preuve du contribuable lorsque celui-ci fait appel d’une cotisation fiscale.