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Searching Content indexed under Litigation, Mediation & Arbitration by Moodys Gartner Tax Law LLP ordered by Published Date Descending.
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1
Triple Canadian Taxation Possible With Subsection 55(2)
This short blog highlights what went wrong, and the court's indifference to the taxpayer's predicament.
Canada
13 Apr 2017
2
Section 84.1: What Brought Poulin And Turgeon To The Table?
Section 84.1 of the Income Tax Act , in its current form, was introduced in 1985, and the provision has always been a source of heartburn for planners.
Canada
25 Aug 2016
3
Half A Loaf Is Better Than None!
The Federal Court of Appeal's (FCA) recent French language decision in the appeal of Gervais considered the use of a sale structure commonly referred to as the "half loaf."
Canada
18 Jan 2016
4
Canadian Challenge To FATCA
In its 2015 budget, the federal government announced a commitment to implement the OECD's common reporting standards starting in July 2017 and reaffirmed Canada's commitment to introduce draft legislation in 2015.
Canada
4 Nov 2015
5
Decision In Canadian Challenge To FATCA Expected Soon
The Canadian Federal Court heard oral arguments on August 4 and 5 in a lawsuit that challenges the law that implements the intergovernmental agreement between Canada and the U.S. relating to the Foreign Account Tax Compliance Act.
Canada
1 Sep 2015
6
A Rare Example Of A One-Client Business Found By The Tax Court To Not Be A Personal Services Business
On August 12, 2015, the Tax Court of Canada ("TCC") released its judgment in C.J. McCarty Inc. v The Queen.
Canada
26 Aug 2015
7
If It Quacks Like A Partnership, It Is A … Corporation?
At the Canada Revenue Agency ("CRA") Roundtable session during the International Fiscal Association Conference on May 28, 2015, the CRA was once again asked to comment on the issue of foreign entity classification.
Canada
3 Jun 2015
8
Solicitor Client Privilege In Tax Matters
In a prior blog post, I said that solicitor client privilege remains strong in Canada.
Canada
26 May 2015
9
Can Canadian Taxpayers Defer A Gain On A Disposition Of Property By Reinvesting The Sale Proceeds Like US Taxpayers Can?
The recent case of Livingston v The Queen from the Tax Court of Canada has once again thrust the replacement property rules in section 44 of the Income Tax Act in the spotlight.
Canada
18 Feb 2015
10
Recent Court Decisions - May 2014
The last year has provided no shortage of exciting and interesting tax cases that tax practitioners can learn from.
Canada
28 May 2014
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