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...
Category: Tax
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...
The Taxation Trio: Fair Market Value, Statutory Interpretation, and Employee Stock Options
Introduction: In Des Groseillers v Quebec (Agence du revenu), 2022 SCC 42, the Supreme Court of Canada (“SCC”) unanimously confirmed the Quebec Court of Appeal’s also-unanimous holding in Agence du revenu du Québec...
General Anti-Avoidance Rule to the Rescue: Canada v Deans Knight Income Corp.
The Supreme Court of Canada (“SCC”) granted leave to Deans Knight Income Corporation (“Deans Knight”) on March 10th, 2022 to appeal a Federal Court of Appeal (“FCA”) decision from August...
