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...

Treaty-shopping is not Inherently Abusive Tax Avoidance in Canada v Alta Energy Luxembourg S.A.R.L.

In Canada v Alta Energy Luxembourg S.A.R.L., 2021 SCC 49 [Alta Energy], the Supreme Court of Canada (“SCC”) unanimously held that taxpayers are entitled to arrange their affairs under international...