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: Tax law
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...
Arm’s Length Transaction or Not? Canada v Loblaw Financial Holdings Inc.
Introduction In Canada v Loblaw Financial Holdings Inc., 2021 SCC 51 [“Loblaw”], the Supreme Court of Canada (“SCC”) examines “one of the most complex tax schemes, with hundreds of definitions,...
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...
