Loblaw Financial Holdings Inc. v Her Majesty the Queen: Banking on Barbados
The Supreme Court of Canada (“SCC”) is usually timid to grant leave to tax law cases. However, earlier this year, we saw the SCC decide MacDonald v. Canada 2020 SCC...
Tagged: Tax
Gladwin Realty Corporation v. Canada : Abusing Specific Anti-Avoidance Rules in Partnerships
Since the creation of the Income Tax Act (“ITA“), there have been taxpayers trying to avoid taxes in any manner possible. Although taxpayers are free to arrange their matters in...
Iggillis Holdings Inc v Canada (National Revenue): What Secrets Can Corporate Lawyers and Their Clients Keep?
When corporate lawyers choose to exchange information with opposing counsel, they do so with a view towards a smooth and confidential closing of their client’s transaction. In particular, the promise...
Rectification is Not Equity’s Mulligan: New Insights on the Law of Rectification in Tax Liability
The Supreme Court of Canada (“SCC”) has recently delivered two companion judgments, Canada (Attorney General) v Fairmont Hotels Inc., 2016 SCC 56 [Fairmont] and Jean Coutu Group (PJC) Inc. v Canada (Attorney...
