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...
Tagged: income tax act
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...
Clash of the Interpretative Titans: Canada v. Canada North Group Inc.
In Canada v. Canada North Group Inc., 2021 SCC 30 [Canada v CNG], the Supreme Court of Canada (“SCC”) considered whether courts can order a super-priority charge that takes primacy...
Her Majesty the Queen v. Cameco Corporation: A transfer pricing case for the books
The Supreme Court of Canada (“SCC”) recently dismissed leave to the Federal Court of Appeal’s (“FCA”) decision of Her Majesty the Queen. v. Cameco Corporation, 2020 FCA 112 [Cameco]. The...
