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.
The Evolution of Control: De Jure, De Facto, and Now “Actual” Control (Under GAAR)
This judgment deals with GAAR. The Federal Court of Appeal reversed the decision of the Tax Court of Canada which had previously allowed the appeal by Deans Knight Income Corporation (“Forbes”) on the basis that GAAR did not apply.
Taxpayers Have the Burden to Demonstrate That a Tax Assessment Is Incorrect by Precise and Probable Proof
Unidisc musique inc. (“Unidisc”) is a company that sells music records. In the normal course of its business, it purchases master tapes of recordings of music (“master records”) in order to make copies of good quality for resale.
SR&ED, a Tale of Two Cases
6398316 claimed expenditures incurred in connection with the construction of a house intended to be “uniquely energy efficient” while staying within the price range of a “regular home”.