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...
Category: 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...
MacDonald v. Canada: Clarity to the Taxation of Derivative Contracts
Taxpayers try to characterize their expenses, gains, and losses in a way that benefits them. Thus, the characterization of expenses, gains, or losses as on account income or capital has...
Lost in Translation: Language Rights in Federal Courts
As the two official languages of Canada, French and English form the bedrock of our legal system, and their usage is a constitutionally protected right found in both the Constitution...
